The following is a non-exhaustive list of terms/descriptors frequently found in New York CPAs' professional titles, roles, job descriptions or in a list of their employment duties:
- "accountant" or "accounting" or "account"
- "auditor" or "auditing" (internal or external)
- "bookkeeper" or "bookkeeping" or "recordkeeping"
- "compliance" or "internal control" or "risk management"
- "construction manager"
- "consulting" or "consultant"
- "controller" or "comptroller"
- "expert witness"
- "financial" or "finance" (such as with "manager," "officer," "analyst" or "planner")
- "human resources / executive recruiting"
- "mergers" or "acquisitions" or "M&A"
- "payables" or "receivables"
- "pension" or "actuary" or "actuarial" or "valuation"
- "portfolio" (such as with "investments" or "real estate" or "securities")
- "tax" or "taxation"
- "treasurer" or "treasury"
These terms/descriptors, which may be found in a variety of combinations and/or with various modifiers (e.g., "chief," "assistant," "professor," "deputy," etc.), usually indicate that the services provided by the CPA are within the scope of practice of public accountancy, even if the CPA is an officer or employee of an enterprise outside of public accounting and is not providing services to clients or customers.
As described in more detail below, a CPA must, if he or she seeks an inactive registration status, submit a written request, via the Public Accountancy Registration Renewal Addendum Form , to the Department, which explains and documents, to the Department's satisfaction, why his or her employment does not include the provision of services that are within the scope of practice of public accountancy, despite the use of any of the above-referenced terms/descriptors and/or modifiers in his or her professional title, role, or job description or in a list of his or her employment duties.
Serving on a Board of Directors or Board of Trustees
A CPA , with an inactive registration, may in some circumstances be permitted to serve on governing boards of commercial and not-for-profit entities, or on committees of such governing boards, without being considered as providing services within the scope of practice of public accountancy. Accordingly, a CPA would not be subject to the CPE requirement, as long as he or she does not provide attest or compilation services, serve as an employee of the organization, or otherwise provide services specifically described as being within the scope of practice of public accountancy. However, if the CPA serves on a publicly held company’s governing board or committee and becomes the designated financial expert, as defined by the Sarbanes Oxley Act of 2002, he or she must maintain an active registration and be in compliance with the CPE requirements.
Preparing Tax Returns for Family Members
A CPA with an inactive registration may be permitted to prepare income tax returns, and other tax returns, for oneself and their family members, without being considered as providing services within the scope of practice of public accountancy, as long as the licensee does not perform these services for a fee, is not on the Internal Revenue Service’s Tax Preparer Identification Number (PTIN) registry, and does not sign the tax returns as a paid preparer. Otherwise, the CPA must be in compliance with the CPE requirements and maintain an active registration.
Teaching a college course, CPA review course, or CPE course
A CPA who teaches a college level accounting course; a CPA review course for the CPA examination; or a formal CPE course offered by an approved CPE provider must be in compliance with the CPE requirements and maintain an active registration.