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Letter to VBOA on historical references to CPA licensure

June 16, 2023

Wendy Lewis, CPA
Incoming Chair
Virginia Board of Accountancy
9960 Mayland Drive, Ste. 402
Richmond, VA 23233

RE: Historical References to CPA Licensure

Dear Ms. Lewis:

On behalf of the nearly 13,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA
has reviewed the proposed changes to Virginia Board of Accountancy (VBOA) Guidelines for
Disposition of Cases Involving the Unlicensed Use of the CPA Title by a Former Licensee. Our
review focused on the potential unintended consequences of item II.a. Disciplinary guidelines
for use of the CPA title with a qualifier in manners such as skills, licensing, or biographical

The VSCPA does not believe this type of reference to prior CPA licensure constitutes unlicensed use of the CPA title and therefore should not be considered a violation. While we understand the VBOA intends to clarify this through a future statute change, we offer the following additional feedback for your consideration in the interim:

  • This interpretation as presented in the guidelines may represent a Constitutional violation and we encourage you to review the Central Hudson Test | The First Amendment Encyclopedia (mtsu.edu) for reference.
  • This interpretation is inconsistent with the intent of the statute, which was to prevent unlicensed CPAs from presenting themselves as being currently licensed to practice public accounting and/or imply current expertise in accounting.
  • The interpretation puts former licensees on unequal footing with third parties not subject to the authority of the VBOA who may reference prior licensure of an individual.
  • Preventing former licensees from referencing their career as a CPA harms the pipeline by making it nearly impossible to share their career with others aspiring to have a career as a CPA.
  • This interpretation does not align with the Uniform Accountancy Act, which does not prohibit historical references to CPA licensure.
  • We are not aware of any other accountancy jurisdictions with a similar restriction.
  • Given all of the attacks on licensure in general, we are concerned this interpretation could be seen as board overreach similar to what was found in the North Carolina Dental case.

We understand the importance of monitoring and enforcement with respect to unlicensed use of the CPA title. However, we encourage the VBOA to consider whether this particular interpretation aids in protecting the public. Additionally, we recommend the VBOA survey other jurisdictions.

We sincerely thank you for the opportunity to comment, and we appreciate your consideration of our input throughout this process. Please feel free to contact me or VSCPA Vice President, Advocacy Emily Walker, CAE, at (804) 612-9428 or [email protected] if we can be of further assistance.


Stephanie R. Peters,
CAE President & CEO
Virginia Society of CPAs

CC: Patrick Cushing