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These are frequently asked questions about CPA Firms:  
  What is the definition of Accounting Services?
What is the definition of Attest and Compilation Services?
Do I need to be registered as a firm?
After I’m registered, are there any ongoing notification requirements?
How are Arizona CPA firms impacted by peer review?
What is Facilitated State Board Access?
What should be considered when naming my firm?
How do I change the name of my firm?
What happens if a partner leaves? Do we have to change the firm name?
How often does my firm's registration renew?
How much does it cost to renew my firm's registration?
How do I cancel my firm’s registration?
My firm’s registration is currently suspended, can I provide attest or compilation services?
Do I have the option to relinquish my firm registration?
Can I reinstate my firm’s registration if it has been cancelled, expired, relinquished or revoked?
 
   
 What is the definition of Accounting Services?  
  Accounting Services means services that are commonly and historically performed by accountants, including recording or summarizing financial transactions, bookkeeping, analyzing or verifying financial information, reporting financial results, financial planning, or providing attest services, compilation services, tax services or consulting services.
   
 What is the definition of Attest and Compilation Services?  
  Attest Services means the following services to be performed by the holder of a certificate issued by the board:
  1. Audits or other engagements to be performed in accordance with the Statements on Auditing standards adopted by the American Institute of Certified Public Accountants (AICPA).
  2. Reviews of financial statements to be performed in accordance with the Statements on Standards for Accounting and Review services adopted by the AICPA.
  3. Any examination of prospective financial information to be performed in accordance with the Statements on standards for Attestation Engagements adopted by the AICPA.
  4. Any engagement to be performed in accordance with the Standards of the Public Company Accounting Oversight Board or its successor.
  5. Any examination, review or agreed on procedure engagement to be performed in accordance with the statements on Standards for Attestation engagements adopted by the AICPA, other than an examination described in subdivision (c) of this paragraph.
Compilation Services means:

Providing a service of any compilation engagement to be performed in accordance with the Statements on Standards for Accounting and Review Services.

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 Do I need to be registered as a firm?  
  Pursuant to A.R.S. § 32-731, the following must register with the Board as a CPA firm:
  • Partnership, PC, PLLC, LLC, or LLP that meets all of the following criteria:
    • Has a simple majority of the ownership, in terms of direct and indirect financial interests and voting rights, that belong to holders in good standing1/ of certificates or licenses as CPAs in any jurisdiction2/.
    • Has an office in this state.
    • Either:
      • Provides attest or compilation services; or
      • Uses the CPA designation in its firm name.
  • Sole Proprietorship3/ that meets all of the following criteria:
    • Has an owner that is a CPA in good standing in this state.
    • Has an office in this state.
    • Either:
      • Performs attest or compilation services.
      • Uses the CPA designation in its firm name, unless the firm name is the name of the sole proprietorship as registered with the Board.
  • An individual that meets all of the following criteria:
    • Is a CPA in good standing in this state.
    • Performs attest or compilation services in this state, other than as an owner or employee of a sole proprietorship or business organization required to register as described above or in the capacity as an employee of a governmental entity.

Once registered with the Board as a CPA firm, you need to maintain the above-applicable requirements in order to operate as a CPA firm. Failure to do so may result in revocation of the CPA firm’s registration, pursuant to A.R.S. § 32-742(A), unless granted an extension of time to comply with firm registration requirements pursuant to A.R.S. § 32-731(F).

1/ “Good Standing” means for an individual, a status that allows the individual to use the CPA designation and to perform accounting services for a fee or other compensation; which, in Arizona, means “Active” or “Probation,” but which may be a different status in another jurisdiction.

2/ “Jurisdiction” means the 50 states of the United States, District of Columbia, U.S. Virgin Islands, Guam, the Commonwealth of the Northern Mariana Islands or Puerto Rico.

3/ “Sole Proprietorship” means a business that is owned by one individual and that does not have a legal distinction between the owner and the business.
a helpful hint Helpful Hints – CPA Designation in Firm Name

If the CPA designation is used in the business name as any of the following:
  • As trademarked with the Secretary of State (sole proprietors/individuals)
  • As organized or incorporated with the Arizona Corporation Commission (partnership, PC, PLLC, LLC, or LLP)
  • As certified or registered with the Arizona State Board of Accountancy (sole proprietors/individuals/partnership, PC, PLLC, LLC, or LLP)
You must apply for or renew an existing firm. If you do not want to register a firm, due to the use of the CPA designation, you may do one of the following:

Partnership, PC, PLLC, LLC, or LLP
  • Change your business name to exclude the CPA designation, and if currently registered as a firm, submit a cancelation order with the Board.
Sole Proprietors or Individuals
  • Submit a name change with the Board to amend your name as certified by and registered with the Board to exactly match your business name.
  • Change your business name to exactly match your name as certified by and registered with the Board, and if currently registered as a firm, submit a name change form with the Board.
The following FAQs may be helpful.

What should be considered when naming my firm?

How do I change the name of my firm?

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 After I’m registered, are there any ongoing notification requirements?  
  Yes, pursuant to A.R.S. §32-731(E), you are required to notify the Board in writing within one month of any change in owners that results in less than a simple majority of the ownership in terms of direct and indirect financial interests and voting rights that belong to holders in good standing of certificates or licenses as certified public accountants in any jurisdiction.

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 How are Arizona CPA firms impacted by peer review?  
  Pursuant to A.A.C. R4-1-454, each firm that performs attest services or compilation services will need to complete a peer review within the three years immediately preceding the firm's registration date. For a further review of the regulation governing peer review, please see the Peer Review page under the Firms tab on this website.

If the firm accepts an engagement, which for the first time will require the firm to complete a peer review, pursuant to A.A.C. R4-1-454(H)(2)(b):

The firm agrees to notify the Board within 90 days after accepting an attest services or compilation service engagement and shall enroll in a Board-approved peer review program with a due date, in compliance with the Standards for Performing and Reporting on Peer Reviews 18 months from the year-end of the initial engagement accepted. For example, if the engagement's year end is 12/31/17, the firm must complete a peer review by 6/30/19.

NOTE! The Peer Review process is often more extensive and expensive to complete than a registrant may realize. It is advised that a registrant not perform attest or compilation services that would subject the firm to peer review without first inquiring with the California Society of CPAs (CSCPA) Peer Review program to better understand the full process.

  1/Firms that performed non-disclosure compilations for financial statements with a period ending before January 1, 2018 are not subject to peer review.

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 What is Facilitated State Board Access?  
  The Facilitated State Board Access (FSBA) is a process that addresses the demand for greater peer review transparency. This is a program that the American Institute of Certified Public Accountants (AICPA) created to help the profession keep up with the evolving changes in the business and regulatory environments.

For firms whose peer reviews are scheduled before January 1, 2018, the firm shall submit peer review documents directly to the Board. For firms whose peer reviews are scheduled after January 1, 2018, the firm must allow the sponsoring organization (California Society of CPAs) to make the peer review documents accessible to the Board via the FSBA process.

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 What should be considered when naming my firm?  
  The Board has a statute and rule that addresses firm name issues:
  • A.R.S § 32-731(I) states that a registrant, which means any CPA or CPA firm registered with the Board, may not use any firm name other than the firm name that is registered with the Board.
  • A.A.C. R4-1-455.03(C) provides thatPursuant to A.A.C R4-1-455.03(C), a registrant shall not use a professional or firm name or designation that is misleading about the legal form of the firm, or about the persons who are partners, officers, members, managers, or shareholders of the firm, or about any other matter. A firm name or designation shall not include words such as “& Company,” “& Associates,” or “& Consultants” unless the terms refer to additional full‐time CPAs that are not otherwise mentioned in the firm name. (See examples of possible misleading firm names below.)

Examples of firm names that would be considered misleading include, but are not limited to, the following:

  • The CPA firm name includes the plural form of the CPA designation, when only one owner in the firm is a CPA.
  • The CPA firm name includes the name of a non-CPA owner of the firm.
  • The firm name includes the use of “& Company,” “& Associates,” “& Consultants,” “Group,” or other similar descriptor, when the firm does not have at least two CPA owners not already named in the firm name, or two additional CPA employees with the firm, in addition all named owners.
  • The CPA firm name implies the existence of a legal business entity when the firm is not organized or incorporated with the Arizona Corporation Commission as such (e.g., the use of P.C., PLLC, LLC, or LLP).
  • The CPA firm name implies certain favorable results can be achieved or creates unjustified expectations (e.g., Arizona’s Best Accounting Firm Ever, PLLC).
  • The CPA firm uses a doing-business-as name (e.g. CPA firm uses the firm name “Smith Financial” when it is registered with the Board as “John Smith, CPA, PLLC”.)
Please see the following statute to learn more about the naming requirements for a domestic professional corporation or a foreign professional corporation:
 
      Corporation Name

  Please see the following statutes to learn more about the naming requirements for limited liability companies, professional limited liability companies, and limited liability partnerships composed of certified public accountants:
 
      Limited Liability Company Name
      Professional Limited Liability Company Name
      Limited Liability Partnership Name

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 How do I change the name of my firm?  
  If you own a firm, changes to the firm’s name require the Board's Executive Director's approval and can be submitted for review using the Firm Name Change Application Form. Please see A.R.S. § 32-731(I) and A.A.C. R4-1-455.03(C) for more information about form of practice and name changes.

a helpful hint Helpful Hints – A.R.S. § 32-731(I) – A registrant, which means any CPA or CPA firm registered with the Board, may not use any firm name other than the firm name that is registered with the Board.

a helpful hint Helpful Hints - A.A.C R4-1-455.03(C) - A registrant shall not use a professional or firm name or designation that is misleading about the legal form of the firm, or about the persons who are partners, officers, members, managers, or shareholders of the firm, or about any other matter. A firm name or designation shall not include words such as “& Company,” “& Associates,” or “& Consultants” unless the terms refer to additional full‐time CPAs that are not otherwise mentioned in the firm name.

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 What happens if a partner leaves? Do we have to change the firm name?  
  Should the firm lose a partner, the firm is not required to change the firm name, pursuant to A.R.S. § 32- 747(C). The law provides the right to the continuous use of a partnership name, or a modification of the name, by successor firms formed by the remaining partner(s) or added partner(s) even though the individuals whose names are included in the firm name are not partners.

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 How often does my firm's registration renew?  
  Pursuant to A.R.S. § 32-730, the Board requires every CPA firm to renew its registration on a biennial basis. However, the timing of the registration depends on whether the firm is:
 
  1)   A “business organization” which means a partnership, professional corporation (PC), professional limited liability company (PLLC), limited liability company (LLC) or limited liability partnership or any other entity that is recognized by the Board and that is establish under the laws of any state or foreign country. “Sole Proprietorship” means a business that is owned by one individual and that does not have a legal distinction between the owner and the business.
  2)   A “sole proprietorship” which means a business that is owned by one individual and that does not have a legal distinction between the owner and the business.
  3)   An “individual” which means a CPA that IS NOT an owner or employee of a business organization or sole proprietorship or an employee of a governmental entity.
  A business organization shall renew during the board-approved month in either an even or odd numbered year, depending on whether the firm registration was initially board-approved in an even- numbered or an odd-numbered year.

  A sole proprietorship or individual shall renew during his/her birth month in either an even or odd numbered year, depending on whether the year of their birth is an even or odd numbered year

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 How much does it cost to renew my firm's registration?  
  Pursuant to A.A.C. R4-1-345(C)(2), the biennial registration fee for each CPA firm is $300 per registration period. A late fee of $50 will be assessed if the firm's renewal is not received on time. However, pursuant to A.R.S. §32-729, a registration fee is not charged for the registration of additional offices of the same firm or for the registration of a sole proprietorship1/ or an individual2/ who is required to register as a firm pursuant to A.R.S. § 32-731 (see FAQ question: “Do I need to be registered as a firm?”).
 

1/A “sole proprietorship” means a business that is owned by one individual and that does not have a legal distinction between the owner and the business. A “sole proprietor” means the owner of a sole proprietorship.

2/An “individual” means a CPA that IS NOT an owner or employee of a business organization or sole proprietorship or an employee of a governmental entity.

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 How do I cancel my firm’s registration?  
  Please select this link to learn more

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 My firm’s registration is currently suspended, can I provide attest or compilation services?  
  Pursuant to A.R.S. § 32-731(B), attest or compilation services shall be provided only through a registered firm in good standing in this state. Any attest or compilation services reports issued by a firm must be signed by a person who is certified pursuant to this chapter or qualified to exercise the limited reciprocity privilege pursuant to A.R.S. § 32-725(G).
a helpful hint Helpful Hints – A.R.S. § 32-731(J)(2) – For a firm, “Good Standing” means a status that allows the firm to use the CPA designation. Therefore, a status such as “suspended”, which disallow the firm from using the CPA designation, would further prohibit the firm from providing attest or compilation services while suspended.

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 Do I have the option to relinquish my firm registration?  
  A.R.S. § 32-730.06(A) allows a firm to relinquish its registration pending or in lieu of an investigation or a disciplinary proceeding or while under a disciplinary order. The Board shall consider a relinquishment and may determine whether to accept the relinquishment and if accepted shall issue an order documenting its decision.

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 Can I reinstate my firm’s registration if it has been cancelled, expired, relinquished or revoked?  
 

Firm registrations can be reinstated from cancelled, expired, relinquished, or revoked status pursuant to A.R.S. § 32-732.

Cancelled Firms: Pursuant to A.R.S. § 32-732(E), an individual, sole proprietor or business organization whose firm registration has been cancelled may request that the firm registration be reinstated if the individual, sole proprietor or business organization does all of the following:

  1. Files an application for reinstatement on the form prescribed by the Board and pays the reinstatement application fee pursuant to A.R.S. § 32-729.
  2. Meets the requirements of A.R.S. § 32-731.
  3. On Board approval of reinstatement, pays the registration fee pursuant to A.R.S. § 32-729.

Expired, Relinquished, or Revoked Firms: Pursuant to A.R.S. § 32-732(F), an individual, sole proprietor or business organization whose firm registration has expired or been relinquished or revoked may request that the firm registration be reinstated if the individual, sole proprietor or business organization meets all of the following requirements:

  1. Files an application for reinstatement on the form prescribed by the Board and pays the reinstatement application fee pursuant to A.R.S. § 32-729.
  2. Meets the requirements of A.R.S. § 32-731.
  3. On Board approval of reinstatement, pays the registration fee pursuant to A.R.S. § 32-729.
  4. Demonstrates through substantial evidence presented to the Board that the firm is completely rehabilitated with respect to the conduct that was pending or outstanding at the time the registration was relinquished or revoked or that occurred before or after the registration expired. Demonstration of rehabilitation includes evidence of the following:
    1. The firm or any owner of the firm has not engaged in any conduct that, if the firm had been registered during the period the conduct occurred, would have constituted a basis for revocation or suspension pursuant to A.R.S. § 32-741.
    2. The firm has addressed or remediated any complaints, investigations or board-ordered requirements that were pending or outstanding at the time of expiration, relinquishment or revocation.
    3. The firm has made restitution as ordered by the Board or by a court of competent jurisdiction as a result of any violation of this chapter or rules adopted pursuant to this chapter.
    4. Other evidence of rehabilitation that the Board deems appropriate.
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