[Anonymous]

Hi All,

Long time lurker, first time poster. Thanks for helping me get through these exams!

I have officially passed all four parts of the exam and in the process of applying for a non-reporting CPA license though Massachusetts (https://www.mass.gov/ocabr/docs/dpl/boards/pa/apnonrep.pdf). I am opting for the non-reporting designation due to the fact that I am not working at an accounting firm, but in a corporate role (accounting/finance). Since I have my Masters in Accounting I am able to bypass the 1000 hour requirement. The non-reporting license works for me as I don’t ever intend on issuing reports on financial statements in my career.

I am currently applying in MA, but my job will be relocating me to Indiana in the next 3-4 months. Has anyone had any luck transferring a non-reporting license to a state that does not offer a non-reporting license? It would be a shame if I put in all this hard work and I wasn’t able to transfer the license.

Thanks in advance.

[neika822]

Question – it's not required to have 1000 attest hours OR a year in public, correct?

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

@neika, with a masters in accounting, business, or tax and 150 credits, you can become licensed as CPA in MA but the license is non-reporting. You then need 1000hours in public to later upgrade to a full reporting license.

The state of Colorado allows an education in lieu of experience option, which expires in 2015. This option allows one to become a Colorado CPA with a masters and 150 credits and no work experience but there are some other specific credit requirements (e.g. you would need to have 6 credits in auditing).

The Colorado education in lieu of experience option will no longer be there in 2015 and by then Colorado is going to become a substantially equivalent state.

What I don't understand is – if you get a non-reporting license in MA, is it going to be impossible to become licensed in another state without first getting those 1000 hours to upgrade oneself to a full-reporting license in MA?

[neika822]

@highmileagedude – thanks for clearing that up. That's what I had assumed, but just wanted it clarified since MA doesn't like to use clear language.

That's also a question I'd like cleared up – about the reciprocity. I have no plans on leaving MA, but what if I do? They're not clear on this either.

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

@neika822 Thanks – I hold a non-reporting in MA, and recently moved to another state. And to be honest, I still really have no idea what the answer to this question is. My concern is that, in other states and at NASBA, they may not be aware that there is such as a thing as a non-reporting license in that state called Massachusetts. I should know in a few weeks. When I call the state board where I'm seeking reciprocal licensure, they tell me to call NASBA. The NASBA person gave me great news that I'm fine, but I just hope he/she understood my circumstances with non-reporting. ….the NASBA person I spoke with just told me simply that as long as the MA license is active then it should be fine? (well, of course it's active, but it's a non-reporting license – so it's restricted right?).

Let's say I've got my MA non-reporting license, and I later decide I don't want to go the 1000 hours because I'm moving to another state and I can meet the experience requirement of another state (which differs from MA. e.g. Colorado where you can go education in lieu of experience OR 1 year (doesnt have to be 1000hours attest) under supervision of an active CPA)…….Can I then apply as a new applicant to that other state, as opposed being forced to go the reciprocity route? Or am I now stuck with a non-reporting MA license where there is NO OTHER OPTION but to get 1000 hours of attest experience? This is what I don't understand.

[neika822]

I'd try to get what NASBA said in writing, and keep that for when you apply to the other state.

There's two sides – since MA is fully equivalent, and there's no mention to exceptions, this should work. I would imagine that if this was explicitly not allowed, it would be stated somewhere. On the other hand, should we have to qualify for the other state's experience requirement? Since what mla said above, everyone would be jumping on this. It's not necessarily “fair” that we don't have experience requirements when other states do. But then we can just NEVER move to another state?

There has to be an instance of another person trying to do this. Somewhere out there, there has to be someone with a non-reporting license who moved and was either able to or not able to gain reciprocity. I've been researching this for about a year now, and there is NO information out there with specifics.

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

“There has to be an instance of another person trying to do this. Somewhere out there, there has to be someone with a non-reporting license who moved and was either able to or not able to gain reciprocity. I've been researching this for about a year now, and there is NO information out there with specifics.”

I'm trying to do it right now 🙂

I'll let you guys know what happens.

I'll get to find out this —-> Will I have to explain to a new employer out of state that, yes, I'm a CPA in MA, but because I got a non-reporting in Massachusetts, (they'll be like – non reporting what's that? is it active?) I have no other options to practice public accounting as a CPA out of state now OTHER THAN to get those 1000 hours of attest to upgrade my MA license, before I can even consider a reciprocity route? I'm willing to apply as a new applicant in the state I'm now working in, but is that allowed if I'm already licensed nonreporting in MA?

[neika822]

All very good questions! Keep us updated on what you find out!

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

These are all the sources of info I've looked through, along with phone calls to NASBA.

“If the candidate has no CPA experience or no report (attest) experience in his/her public accounting experience, the privileges of their license will be restricted to all accounting services, except issuing reports on financial statements. This restriction is designated as a non reporting license, but only the Board and the non reporting licensee will be aware of this restriction unless a member of the public were to inquire. ” – https://www.mass.gov/ocabr/licensee/dpl-boards/pa/faqs.html

So a MA non-reporting license is everything a real license to the public is, (it's listed the same as a regular CPA license on MA's board website), just that you CANT issue reports on financial statements.

A good thing about MA is that an MA license, if unrestricted (BUT…non reporting is restricted, right?), has a lot of mobility with no need to become licensed elsewhere really because of the new CPA mobility stuff…because when I check https://www.cpamobility.org/

and put MA as principal place of business and choose almost any other state, I get (which is awesome news):

“Individual mobility is available (with no further filing or fee) if you hold an active unrestricted CPA license in your principal place of business. “CPA license” means a CPA license granted by the state board after all education, exam and experience requirements have been met.”

And when I check https://www.nasba.org/licensure/substantialequivalency/

“Under Section 23 of the Uniform Accountancy Act (UAA), a CPA with a CPA license in good standing from a jurisdiction with CPA licensing requirements that are essentially equivalent to those outlined in the UAA (degree with 150 hours, minimum 1 year experience and successful completion of the Uniform CPA Examination) may be granted a privilege to practice in another jurisdiction that is not the CPAs principal place of business.”

it doesn't have a star next to Massachusetts, which may be what makes NASBA person tell me that as long as the Massachusetts license I have is ACTIVE, (again, do they know there's a such thing as a non-reporting?), you're OK to apply for reciprocity in the other state?

FINALLY, the state in which I'm applying for reciprocal licensure just says this:

“Holds an active license from a substantially equivalent jurisdiction”

My interpretation -> Yes. A non-reporting CPA license in Massachusetts is active. And Massachusetts is a substantially equivalent jurisdiction. But, you may be unaware that there's a such thing as non-reporting in Massachusetts.

Haha I'm sure in a few years these things will be a lot less confusing.

[neika822]

I think the key word is “unrestricted”: “if you hold an active unrestricted CPA license in your principal place of business.” Since the non-reporting license is NOT unrestricted ” the privileges of their license will be restricted to all accounting services,” then my best guess would be they are not reciprocal. However, I wonder if there are other solutions to this. Like you said, can you re-apply for an additional license with the state you're moving to? I haven't looked much into how reciprocity or having multiple licenses works (is that even possible?) since I'm still taking the exam.

I would try to tell NASBA that you have a non-reporting RESTRICTED license, and maybe she'll understand what you're talking about.

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

@neika822, I agree that mobility with no filing or fees is probably NOT allowed, because the non-reporting is restricted.

But, when applying for reciprocity in the new state, if the state I'm applying in simply says that for a reciprocal license application: “Holds an active license from a substantially equivalent jurisdiction,” I may meet that requirement. NASBA person I spoke with said I did. And I said so it doesn't matter that it's non-reporting? Well is it active? Yes. Then you're fine.

I think I also meet the experience requirement in that state but would have to apply as a new CPA applicant, which, again, I'm not sure is allowed because I already hold a non-reporting license in MA.

[neika822]

I wish there was a different experience requirement in MA. For the non-reporting license, if you don't have your master's (but you have 150 credits) you need a year of public, which could be substituted for 3 years working under a CPA outside of public. I wish the full reporting license had that or there was a way we could more easily convert from a non-reporting to a reporting. It's frustrating. I have 1000 attest hours but I'm short on the year in public (by 13 days).

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[HighMileageDude]

The Colorado CPA license might be the best bet at this point for those with no work experience wanting to become CPAs because, unlike a Massachusetts non-reporting license, the Colorado CPA license via the “education in lieu of experience” route is entirely unrestricted – there's no such thing as a non-reporting restricted CPA license in Colorado. The only thing (and the reason I chose to go the Massachusetts route instead of Colorado) is Colorado is (but maybe not anymore?) still in process of becoming substantially equivalent so mobility might to be limited if you wanted to actually practice public accounting in another state someday. But Cpamobility.org shows that a Colorado CPA can perform audit engagements in states like NY and MA without any filing fee so mobility may be much better these days.

By 2015, Colorado is going to require 150 credits and experience because it's getting rid of the “education in lieu of experience” option. Colorado is going to then be considered substantially equivalent in 2015.

So, the way I see it, from now until 2015, CPA Candidates from all over with education but no experience may be taking advantage of the education in lieu of experience thing in Colorado. Colorado has (or is soon getting) good mobility options, which may not have been true in the past.

As MLA said above, everyone would be jumping at it if you could get it this way, right? Maybe It sounds too good to be true..Well, the only two states that allow a CPA without any type of work experience are Colorado and Massachusetts. Some other states are considered 2 tiered – meaning that they have an option for obtaining a CPA “certificate” but not a full license until the work experience (and perhaps other requirements) have been fully met.

Let's look at some examples here:

The following is copied and pasted from NASBA website…

https://www.nasba.org/licensure/substantialequivalency/

“Colorado**

Connecticut*

Florida

Massachusetts

New York

Rhode Island

South Carolina

* These states are two-tier. A certificate is initially obtained which does not allow the individual full privileges as a CPA. After additional requirements are met, the certificate holder may receive a license or permit. Only those CPAs holding an active license or permit are considered substantially equivalent.

** These states currently have more than one path to licensure, with at least one path meeting the 3E criteria of the UAA (baccalaureate degree or higher with 150 semester hours, minimum 1 year experience and Uniform CPA Examination). Based on their current laws/rules, these states have passed legislation terminating the alternative paths within the time limits set forth by the UAA. (The ** notation is informational and does not affect a state’s current SE status. At such time as the alternate paths to licensure expire and the 3E criteria is the sole path to licensure in these states, the ** notation will be removed.)”

As you can see, most states (such as Colorado) are moving toward the “3E criteria of the UAA (baccalaureate degree or higher with 150 semester hours, minimum 1 year experience and Uniform CPA Examination)”

You take a 1 star state like Connecticut and the rule is very clear. it's a 2 tiered state, so unless your license is an active license (and not just a certificate), it's not considered substantially equivalent.

You take a 2 star state like Colorado, and it's got “more than one path to licensure” (because of the education in lieu of experience option) – which is disappearing in 2015, at which time it will have the “3E criteria of the UAA (baccalaureate degree or higher with 150 semester hours, minimum 1 year experience and Uniform CPA Examination)” as the sole route and being considered substantially equivalent. So, if you've passed the CPA exam, you have education but ZERO work experience, the solution is simple – get a CPA license in Colorado via the education in lieu of experience….wait until 2015 when the education in lieu of experience OPTION is gone and the state is considered substantially equivalent…and you're able to practice anywhere else since Colorado will be considered a substantially equivalent state by then, right?

NOW, you take a ZERO star like Massachusetts, and it seems that Massachusetts is substantially equivalent – meaning that if the license is active, even if it's non-reporting, then it's substantially equivalent? It seems it would make sense for Massachusetts to have 2 stars there like Colorado and at least recognize that because there's more than one route to licensure (non-reporting), it doesn't exactly MEET the “3E criteria of the UAA”…unless in Massachusetts' case they're not considering the non-reporting to be a real license, even though it's presented to the public as such????????????????

[HighMileageDude]

@neika822 I know what you mean by the non-reporting where even if you have your 150 and are applying in Massachusetts, you MUST have a graduate degree in accounting, business admin, or law to get the non-reporting (restricted?) CPA license.

Requirements for a Massachusetts non-reporting (restricted) license

source – https://www.mass.gov/ocabr/licensee/dpl-boards/pa/regulations/rules-and-regs/252-cmr-200.html#2.07

“Earned a graduate degree in accounting from a program at a nationally or regionally accredited college or university that is further accredited by the Association to Advance Collegiate Schools of Business (AACSB). Programs not accredited by AACSB must be approved by the Board as having substantially equivalent educational program requirements. The Board, or an Educators Credential Committee appointed by the Board, will review the graduate accounting programs of a nationally or regionally accredited college or university to determine if such programs are substantially equivalent to AACSB standards, upon a written request from such college or university. The Educators Credential Committee will consist of at least three accounting educators selected by the Board from the faculty of nationally or regionally accredited educational institutions located in the Commonwealth of Massachusetts;

Earned a graduate degree in accounting, business administration or law from a nationally or regionally accredited college or university. This degree must include 30 semester hours (45-quarter hours) of accounting at the undergraduate level, or 18 semester hours (27 quarter hours) of accounting at the graduate level. The accounting credits shall include coverage in financial accounting, auditing, taxation, and management accounting. In addition, the degree must include or be supplemented by, 24 semester hours (36 quarter hours) of business courses (other than accounting courses) at the undergraduate level or 18 semester hours (27 quarter hours) at the graduate level, or an equivalent combination thereof;”

BUT, if you don't want to get a graduate degree but just have bachelors with 30 additional hours, you might want to look into Colorado's education in lieu of experience. I meet Colorado's except I only have 3 Audit credits as part of my Masters degree and Colorado requires 6 audit credits for the education in lieu of experience.

Source –

https://www.colorado.gov/cs/Satellite/DORA-Reg/CBON/DORA/1251632672682

“These education requirements apply to persons who choose the education in lieu of experience option

to qualify for certification and who apply for certification prior to July 1, 2015.

A. A baccalaureate degree plus an additional 30 semester hours (45 quarter hours) of nonduplicative study or a master's degree or other higher degree;

B. At least 45 semester hours (60 quarter hours) in accounting subjects (combination of

undergraduate and graduate coursework) in such areas as elementary accounting, accounting

theory, accounting practice, managerial accounting, cost accounting, tax accounting, not-forprofit accounting, auditing, governmental accounting and accounting related computer and

information systems. Of the 45 semester hours (60 quarter hours), at least six semester hours

(eight quarter hours) must be in auditing. In order to receive credit for accounting related

computer and information systems coursework, the transcript must indicate an accounting

program code, or the Applicant may furnish other information to indicate an accounting related

course.

C. At least 36 semester hours (48 quarter hours) of courses in business administration which may

be in areas such as upper-division economics, the legal and social environment of business,

business law, marketing, finance, management, organizational, group and individual behavior,

quantitative applications in business and upper division written communication. No more than

nine semester hours (14 quarter hours) shall be in any one area.

D. The courses required by Paragraphs (B) and (C) above shall be taken at or acceptable for transfer

by one or more colleges or universities with approved accounting programs as defined in Rule

2.3.

E. Three semester hours (four quarter hours) of auditing required in Paragraph (B) must address

GAAS. The remaining three semester hours (four quarter hours) may be in advanced auditing or

a subset of basic auditing such as fraud or information technology auditing.”

[neika822]

@HighMileageDude – Thanks! Thankfully I have my master's. I was just complaining that I'm still prohibited from the full-reporting license because of my lack of the experience. I wish there was another way around that (like 3 years of experience under a CPA in any accounting position). So it seems that a non-reporting license is my only option in MA.

R - *77*(02/'13)-Becker & NINJA
A - 71('11); *87*(04/'13)-Becker & NINJA
F - *76*(08/'13)-Becker & NINJA - "server upgrade" survivor
B - 60('11); *82*(10/'13) -Becker & NINA

DONE, DONE, AND DONE.

CPA in Massachusetts; issued 01/24/14

[mla1169]

Neika, call the state board and explain your situation. If you can get those 352 days signed off on, you might be able to make up the difference even volunteering for a CPA for 2weeks. I'm not sure that 1 year absolutely must be consecutive and with the same CPA. I could be mistaken but it's worth asking the question!

FAR- 77
AUD -49, 71, 84
REG -56,75!
BEC -75

Massachusetts CPA (non reporting) since 3/12.

[Author]

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