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ABOUT THE WA STATE BOARD OF
ACCOUNTANCY
The Washington State Board of
Accountancy is a consumer protection
agency that initially qualies and
continues to monitor the professional
performance and ethical behavior of
Certied Public Accountants (CPAs), CPA-
Inactive certicate holders, CPA rms, and
non-licensee CPA rm owners, serving
individual and enterprise consumers in
Washington State.
Unlike most state agencies, the Board
of Accountancy is not funded by public
tax dollars. CPAs, CPA-Inactive certicate
holders, CPA rms, non-licensee CPA rm
owners and CPA examination applicants
pay an administrative fee or reimburse
examination costs to cover all of the
agency’s operating expenses.
We are a very small agency with only
eight employees. We are here to protect
the public interest and provide the
following services:
• Test approximately 2,000 candidates
each year.
• Evaluate the initial qualications of
applicants and rms and approve or
deny licenses.
• Review and monitor the continuing
qualications and performance of
the almost 17,000 individuals and
2,100 rms licensed in Washington.
RECORDS AND YOU
PART ONE OF “STAYING OUT OF TROUBLE”
Eectively managing your records goes a long way toward managing your professional
risk. As a certied public accountant, considerable onus is placed in your custody of client
information and distinguishing among what records must be provided, when and how. Also,
the cost of providing these records is an important consideration. In the Board’s Enforcement
division, the question of client records is often a source of concern. Board rule, or more
specically, Title 4 WAC 4-30-051, is the clarifying rule of guidance.
The What
Records are not all the same. Board rule breaks records into four separate categories: client
provided records, licensee prepared records, supporting records, and working papers. Rule
states that client provided, licensee prepared, and supporting records must be provided to
the client upon request.
What are these dierent types?
• Client provided records are, quite simply, accounting or other records that have been
provided to a licensee by the client.
• Licensee prepared records are those created by the licensee, and are generally the
purpose of the engagement: tax returns, general ledgers, subsidiary journals, and
supporting schedules.
• Supporting records are typically not reected in the client’s books and records, and not
otherwise available to the client. Adjusting, closing, combining, or consolidating journal
entries are just a few examples of documents that support an engagement.
• Working papers would usually hold little interest to a client. Audit programs, analytical
review schedules, statistical sampling results, and analyses guide a licensee’s work, but
are not work product, or supportive of such.
The When
The urgency of conveying records to client upon request varies according to format, and
some of these records are not as readily deliverable as others. “Soon as practical” is the
guidance in the rule, but barring extenuating circumstances, 45 days from date of request is
the deadline.
If a licensee has previously provided a client with a record, there is no obligation to do so
again, barring some unusual circumstance. While such consideration may help in client
relations, a licensee is not required to deliver records that have already been delivered, but
that is a decision up to the CPA.
The How
Some client records may be in a format that is unusable by the client. Licensees may use
software or hardware that makes a record unusable to someone without the same tools.
WAC 4-30-051 requires that the requested records be provided in any format usable by the
client. Today’s world empowers people with more tools than ever before, but what may be
usable by one person may not be the same for another. Discussing the deliverable format
with a client can help prevent any potential hiccup, or redundant work, in the future.
Read more about ‘Records and You’ on page 6.