Mobility is a practice privilege that generally permits a licensed CPA in good standing to practice in a state from outside of their principal place of business without obtaining another license, so long as the licensee meets certain state specific conditions.
For state accountancy boards that have adopted the Uniform Accountancy Act § 23 Safe Harbor language for mobility, this will allow those licensees who had practice privileges prior to a specific date to proceed to practice, so long as they have a license in good standing and no other state specific restrictions apply. Currently, Delaware, New Jersey, Texas, and Pennsylvania have adopted the UAA Safe Harbor Language for Mobility.
As of July 1, 2009:
Individual Practice Privilege - A CPA whose principal place of business is outside of Iowa may provide services in Iowa if such person holds a valid, unexpired license in good standing in the state of their principal place of business that
- is substantially equivalent to a comparable license issued in Iowa; or
- the individual must have individual qualifications that are substantially equivalent to Iowa's licensing requirements.
- The basic qualifications for an Iowa CPA certificate include one hundred and fifty (150) semester hours of education, a baccalaureate or higher degree, passing the Uniform CPA Exam, and one (1) year of qualifying experience or, for an attest practice, two (2) years of qualifying experience.
- Out-of-state CPAs who were not issued a CPA certificate from a state which is substantially equivalent to Iowa and who do not otherwise satisfy substantially equivalent qualifications, are eligible to exercise a practice privilege in Iowa if they satisfy the "four-in-ten" (4 in 10) rule in Iowa Code § 542.19(1)(c).
- Individuals or firms must be licensed to lawfully perform in its principal place of business all public accounting services offered or rendered under a practice privilege in Iowa.
The practice privilege in Iowa is temporary and will cease if the license in the person's or firm's principal place of business expires, is no longer valid or in good standing, or otherwise no longer lawfully supports the conditions of practice privileges in Iowa. The Iowa Accountancy Examining Board may revoke a practice privilege, impose a civil penalty, issue an order to secure compliance, may refer a complaint to the home licensing authority or take additional actions if a person or firm acting under a practice privilege violates Iowa's laws or rules. - Practice privileges extend to any individual who offers or renders professional services, whether in person, by mail, telephone or electronic means, in Iowa, and no notice or other submission shall be provided by the individual.
Firm Practice Privilege/Firm Registration Requirement - Iowa Practice Privilege applies to CPA firms that are licensed to practice as CPA firms in the jurisdiction in which their principal place of business is located for those periods of time in which all of the following conditions are satisfied:
- The out-of-state license is valid, in good standing, and active. The practice privilege ceases if the out-of-state license expires in the jurisdiction of the firm’s principal place of business.
- The out-of-state license is substantially equivalent to a permit to practice issued under Iowa Code § 542.7.
- The license authorizes in the firm’s principal place of business all of the public accounting services the firm performs or offers to perform in Iowa or for clients with a home office in Iowa.
- The public accounting services offered in Iowa or for clients with a home office in Iowa that are obligated under Iowa law to be performed by a CPA are performed by a person holding a certificate issued under Iowa Code § 542.6 or Iowa Code § 542.19, or by a person exercising a practice privilege pursuant to Iowa requirements listed above.
- Practice privileges do not prevent governmental officials or bodies, or other clients from requiring that public accounting services performed in Iowa or for an Iowa client be performed by a person or firm holding an Iowa license.
- The practice privilege in Iowa is temporary and will cease if the license in the person's or firm's principal place of business expires, is no longer valid or in good standing, or otherwise no longer lawfully supports the conditions of practice privileges in Iowa. (Iowa Code 542.20(3)
- The Iowa Accountancy Examining Board may revoke a practice privilege, impose a civil penalty, issue an order to secure compliance, may refer a complaint to the home licensing authority or take additional actions if a person or firm acting under a practice privilege violates Iowa's laws or rules. (Iowa Code §542.20(4))
- Firm registration requirements may apply:
- Individuals providing audit, review or other attest services in Iowa or for a client with a home office in Iowa must practice through a CPA firm that holds an active Iowa permit to practice, or through an out-of-state CPA firm exercising a practice privilege as long as the out-of-state firm is validly licensed in the state of its principal place of business, complies with Iowa’s statutory practice privilege requirements and associated rules, and complies with Iowa’s peer review and ownership provisions.
- Unless Iowa certification is specifically required by a governmental body or client, individual CPAs performing such attest services through an out-of-state CPA firm may either hold an active Iowa CPA certificate or exercise a practice privilege.
Consent to Jurisdiction (See Iowa Admin. Code r. 193A—21.6(4)) - As a condition to exercising the practice privilege in Iowa, the individual and firm consent to the following:
- The personal and subject matter jurisdiction and regulatory authority of the Iowa Accountancy Examining Board;
- The appointment of the regulatory body of the state that issued the license in the principal place of business as the agent upon whom process may be served in any action or proceeding by the Iowa Accountancy Examining Board against the individual and/or firm;
- To supply the Iowa Accountancy Examining Board, upon request and without subpoena, with information or records licensees are similarly required to provide the Iowa Accountancy Examining Board; and
- To promptly cease offering or providing public accounting services in Iowa or for a client with a home office in Iowa if the license in the individual/firm's principal place of business expires or is otherwise no longer in good standing, or if any of the conditions for exercising the practice privilege are no longer satisfied, or if the Iowa Accountancy Examining Board revoked the practice privilege.
Peer Review Requirement (See Iowa Admin. Code r. 193A—20.5) - Individuals providing compilation services in Iowa or for a client with a home office in Iowa need to comply with the peer review provisions of Iowa Code § 542.6(6) or provide such services through a CPA firm, or a substantially equivalent firm that holds a valid license in the firm’s principal place of business and that complies with the peer review and ownership provisions of Iowa Code § 542.7 (CPA).
Additional Requirements - CPAs performing attest services, whether the CPAs are certified in Iowa or exercising a practice privilege, may only do so in a CPA firm that holds a permit to practice in Iowa or in an out-of-state CPA firm exercising a practice privilege in compliance with Iowa Code section 542.20(5) and 542.20(6) and associated rules and the peer review and ownership provisions of Iowa Code § 542.7.
Restrictions
Definitions (See Iowa Code § 542(542.3)) - “Attest” or “attest service” means providing any of the following services:
- An audit or other engagement to be performed in accordance with the Statements on Auditing Standards (SAS).
- A review of a financial statement to be performed in accordance with the Statements on Standards for Accounting and Review Services (SSARS).
- Any engagement to be performed in accordance with the Statements on Standards for Attestation Engagements (SSAE).
- Any engagement to be performed in accordance with the standards of the Public Company Accounting Oversight Board (PCAOB).
- “Compilation” means a service performed in accordance with statements on standards for accounting and review services and presented in the form of financial statements, which provides information that is the representation of management without undertaking to express any assurance on the statements.
- “Practice of public accounting” means the performance or the offering to perform, by a person holding oneself out to the public as a CPA, one (1) or more kinds of professional services involving the use of accounting, attest, or auditing skills, including the issuance of reports on financial statements, or of one (1) or more kinds of management advisory, financial advisory, or consulting services, or the preparation of tax returns or the furnishing of advice on tax matters. However, with respect to licensed public accountants, the “practice of public accounting” shall not include attest or auditing services or the rendering of an opinion attesting to the reliability of any representation embracing financial information.
- “Practice privilege” means an authorization to practice public accounting in Iowa or for clients with a home office in Iowa without licensure in Iowa, as provided in Iowa Code § 542.20.
- “Principal place of business” means the primary location from which public accounting services are performed. A person or firm may only have one (1) principal place of business at any one (1) time.
- “Substantial equivalency” is a determination by the Iowa Accountancy Examining Board that the education, exam, and experience requirements contained in the statutes and administrative rules of another jurisdiction are comparable to, or exceed those required by the Iowa Accountancy Examining Board, or that an individual licensee’s education, exam, and experience qualifications are comparable to or exceed those required by the Iowa Accountancy Examining Board.
Statute and/or Regulation Reference Iowa Admin. Code §§ 193A.20.1 through 193A.20.8
Iowa Admin. Code §§ 193A.21.1 through 193A.21.8
Iowa Code § 542.3(540.20)
Two (2)-Tiered States - For mobility purposes, "CPA license" means a CPA license granted by the state board after all education, exam and experience requirements have been met. A CPA performing services through mobility may only perform the same level of services (attest or non-attest) in the mobility jurisdiction as they are permitted to perform in the home jurisdiction. Please note the following if you are coming from one (1) of the jurisdictions listed:
- An Alabama certificate holder, holding other than an active license with a permit to practice, may not hold out or practice as a CPA in a mobility jurisdiction.
- A Connecticut certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- An Illinois certificate or registered certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- Both a Hawaii CPA license and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- A Kansas certificate holder may not hold out or practice as a CPA in a mobility jurisdiction.
- Both a Montana CPA certificate and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- Both a Nebraska CPA certificate and permit are required in order to hold out or practice as a CPA in a mobility jurisdiction.
- An Oklahoma registrant must hold an active permit In order to hold out or practice as a CPA in a mobility jurisdiction.
Disclaimer: The information contained in NASBA’s Accountancy Licensing Library and CPAmobility.org is for informational purposes only and should not be construed as legal advice or legal opinion. The information is based on current state board of accountancy law and rules which are publicly available. Because board law and rules are continuously changing, there may be a slight delay in law or rule effective dates and the information reflected in these websites. NASBA cannot guarantee a mobility outcome based solely on the information contained in these websites, as additional state factors not listed here may be applicable. It is the responsibility of each CPA licensee or permit holder to be knowledgeable of each state board's current laws and rules in the state(s) in which the licensee intends to practice via mobility.
Click Reciprocal Licensure and/or Firm Registration in the menu bar at the top of this page for additional information or if these practice privilege requirements do not apply to you or your firm. |
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