Attest Hour Sign-Off Issues

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  • #1880470
    lurking_CPA
    Participant

    I'm looking for some advice because I have an unusual situation where I want to get my attest signed off in California, but I'm facing severe push back from all by 1 firm.

    I worked for KPMG, PwC, and a local CPA firm that does governmental audits. I've sent a request for attest hour sign-off to each of them. So far, only PwC seems willing to complete both Part A and B of the hours. My other employers said they will sign-off but will not be certifying Part B – essentially making it worthless.

    Do I have any recourse to appeal this? I currently do not work in public accounting any longer, but I work at the Director level and it's a personal accomplishment for me to want my license to be a “full” attest license.

    I've spent thousands of hours auditing. I've understood that associates who passed the CPA exam have been certified in hours. The issue seems I have short (1 year) tenure at my local firm past employer and KPMG. PwC will be signing off on Part B for all areas except planning – so thought I have enough hours – I'm stuck without that section certified which sucks.

    Any ideas? Suggestions? Advice? I really don't want to have to “go back to public accounting” because I do not plan to in the near and mid-term in my career.

    AUD - 85
    BEC - 85
    FAR - 76
    REG - 75
    FAR  - 67, 47, 60, 76
    REG - 55, 56, 75
    AUD - 59, 73, 85
    BEC - 63, 74, 85

    Ethics - 92

    #2031248
    lurking_CPA
    Participant

    I didn't get any replies to this, but I wanted to share my story in case it happens to somebody else.

    I went ahead and submitted my forms to the board of accountancy knowing I have about 2,000+ hours of attest but I am lacking Part B sign off by any employer for “planning”

    I was told that I might have to appear in front of the qualifications committee on the matter. The whole situation was rather vague because I imagine this is a very infrequent situation.

    So now I am waiting for a letter of acknowledgment from the board. It's unfair that several past employers state I “waited too long” to request a certificate of attest. They fulfilled their legal duty by mailing it in, but refused to sign off Part B.

    It's a little frustrating that so late in my career having done so much audit work to be thrown this barrier.

    AUD - 85
    BEC - 85
    FAR - 76
    REG - 75
    FAR  - 67, 47, 60, 76
    REG - 55, 56, 75
    AUD - 59, 73, 85
    BEC - 63, 74, 85

    Ethics - 92

    #2031590
    Pork Flavored Bacon
    Participant

    What is the letter of acknowledgement? I do not know anyone in your situation but are you saying there is a chance you may not receive licensure?

    #2031659
    ReckedRecked
    Participant

    Attaching the CA experience form link, in case anyone else is interested to read it.
    https://www.dca.ca.gov/cba/applicants/aexp-pub.pdf
    I'd be curious to hear how this ended for you. It seems that perhaps you were not at any employer long enough to reach the planning phase of the audit process, but you were more on the front lines/grunt work end of it?
    Is that correct?

    Memento Mori - Kingston NY CPA & EA (SUNY Albany 2002)

    FAR-93 11/9/17 (10wks, 250 hrs, Roger 1800+ MCQs, Gleim TB 600+MCQs, SIMs)
    AUD-88 12/7/17 (3 wks, 85 hrs, Roger 1000 MCQs no SIMs hail mary)
    REG-96 1/18/18 (6 wks, 110 hrs, 1400 MCQs, no SIMs)
    BEC-91 2/16/18 (4wks, 90 hrs, 1240 MCQs)

    #2072138
    lurking_CPA
    Participant

    So to update on this – I received my general CPA from the State of California. Simultaneous to all the waiting for that, I also had my prior firms submit the certificate of attest for my audit experience. Once the general license was confirmed, there is another form you fill out for attest.

    The result so far was as I expected. Each employer provided me with well over 500 hours, however without “Part B” sign-off from two of them of them. The state board effectively counts hours without “Part B” as 0. One employer gave me 500 hours of signoff but as I expected in all areas except audit planning, meaning I'm an area deficient.

    My options at this point are to find some sidework doing a review, AUP, or smaller audit engagement to get audit hours from a smaller firm or solo practitioner who might be willing to let me work on a job part-time, outright go back to public accounting to audit again and attempt to get 500 hours of experience which includes a slice of planning hours to get coverage, or to challenge my previous employers with the qualifications committee.

    My tenure with most employers were short, but I worked on several first year new clients for one employer who as a solo practitioner just simply blanket refused to sign my hours. He said he only signs off for people who have led engagements as a senior for “years” which would probably the point I'd challenge if I went to QC to petition my case. There is no requirement to “senior” jobs for several years to get sign off – very many associates in the Big 4 get their hours signed off. The text merely asks if the supervisor would be confident of the person performing the tasks with minimal supervision. We disagreed on “minimal supervision”. My old boss seems to think you need to be a borderline manager to qualify. I disagreed because “minimal supervision” does not imply “no review”. Nobody with an attest license would suddenly open their own firm the next day and start signing off audits recklessly either. It's a frustrating California requirement that I think can at times be borderline professional career obstruction. My old boss is simply being “salty”.

    My plan at this point is I'm working with some local CPAs to try to obtain the hours without going to the committee. The qualifications committee I view as a last resort effort. I believe I would prevail, but since they meet quarterly and there is no guarantee I'd win attempting some sidework seems to be the best option at this point.

    Full disclosure, I am absolutely interested in starting my own small firm or solo practice and I wish to be able to provide the full suite of services a CPA can provide which includes compilation, review, and audit. I don't want to be limited to just advisory consulting, bookkeeping, and tax functions as a CPA. I spent too many busy seasons already in public accounting to settle for a ‘general' license.

    AUD - 85
    BEC - 85
    FAR - 76
    REG - 75
    FAR  - 67, 47, 60, 76
    REG - 55, 56, 75
    AUD - 59, 73, 85
    BEC - 63, 74, 85

    Ethics - 92

    #2072306
    jombe
    Participant

    I actually have pretty recent experience w/ appearing before QC Committee to verify my attestation hours.
    Not sure what you mean by “Part B” though. Are you referring to those questions that start w/ “In your opinion…”? Or, the table that summarizes the hrs you spent in each area?

    Anyways, here's how California Code of Regulations define “attest experience.” (California Code of Regulations Section 12.5)
    “This experience shall include all of the following:
    (1) Experience in the planning of the audit including the selection of the procedures to be performed.
    (2) Experience in applying a variety of auditing procedures and techniques to the usual and customary financial transactions included in financial statements.
    (3) Experience in the preparation of working papers in connection with the various elements of (1) and (2) above.
    (4) Experience in the preparation of written explanations and comments on the work performed and its findings.
    (5) Experience in the preparation of and reporting on full disclosure financial statements.”

    As you can see, they require experience in planning, testing, and reporting via f/s. It's “AND”, not “OR.”

    Unfortunately I, like most people in similar boat I assume, only found out about the exact definition of attest experience 5 months after I submitted my application and my form showed very low hours on planning and reporting, as I've only spent 2 years in public accounting as an audit associate.

    W/ all that said, I appeared before QC on Oct'18 and had an interview w/ two very experienced CPAs who pretty much just wanted to make sure I had at least competent understanding of planning/reporting. I would make sure you can talk about how you'd compute materiality, assess risk, and some of audit techniques + how you'd prepare disclosures, etc. My interview took about ~45 mins. They will let you know on-site whether they will approve you for a license w/ attest authority or not. Paperwork after that takes weeks though, LOL!

    Also, if the firms you worked for are located in California, they will make the Partner come in for the appearance and CBA told me the Partner can't refuse such request. If they do, they are sanctioned. My interviewers said I was the first one they ever interviewed that showed up w/o a partner, and that's only because out-of-state firm signed off on the form. I am sure I got some sympathy points by showing up alone. 😀

    Another thing is, which I know won't make you feel any better, that a lot of firms have document retention policies and they throw away details of hrs of their employees after certain period of time. I am not saying I agree w/ the firms who refused to sign off on your form, but that's actually a pretty common reason I've heard from people I know who tried to get their CPA after leaving public accounting for X number of years.

    Long story short, I got a letter stating I met all the requirements to obtain a CPA license w/ attest authority 2 1/2 weeks ago and I sent my licensing fee in. Still waiting on my license #.

    AUD - 99
    BEC - 91
    FAR - 94
    REG - 96
    --------------------------------------------
    Done with exam. On with life.
    #2163814
    Heather
    Participant

    Hi there,

    For your sign off for hours request at KPMG where did you send the request? I am transferring my license from Washington State and worked at KPMG 20 years ago. I was fully licensed in Washington so they saw my attest hours certificate, but I don't know how to get that again. I will be so happy when this is completed. NEVER let your license lapse is my advice as an older person :).

    Thank you for any help!

    #2193454
    lurking_CPA
    Participant

    Hi everybody I have an update about my situation, but first to reply to Jombe:

    Yes, “Part B” as in the “in your opinion can so & so perform the tasks with minimal supervision”. Most of my hours were grunt work, however I did do interim control work + walkthroughs, understanding the entity work, preliminary flux, materiality calculations, and the selection of audit procedures process – all that good preliminary procedure stuff and I am confident I could speak eloquently on it. You know just unfortunately the solo practitioner I worked for where I had most of the planning work just flat out refused to sign my hours because candidly he's a prick and I think a lot of other CPA firm owners competing in the same sector think he's a prick too who has like a 90% turnover rate in his hires at every level because he treats them like dirt. He's now struggling to hire seniors and managers to run the jobs he's underbid out. I can't say I feel sorry for him at all. Doesn't help the guy flaunts his Rolex, his stupid BMW, and talks about eating at Michelin star restaurants all the time. Probably compensating for something if you ask me.

    KPMG did end up having all my hours still from the system and all the original workpapers, but the office managing partner flat out refused to sign my paperwork. The senior manager had apparently reviewed my workpapers and even though i had over a thousand hours of grunt work could not find it in his heart to even sign me off for substantive testing even though I was an experienced hire. The OPM didn't talk to my senior and manager from that engagement and I confirmed this by confronting the senior manager. So they claimed they would go back and talk to those two people and see if the fact pattern changed. Of course, those two didn't pull through for me. My old senior basically said he's “not going to exaggerate my work” – whatever that meant which probably basically meant he's going to claim he doesn't remember anything. The manager was a piece of work who went MIA during busy season on a several week vacation with her fiance while we were working 65+ hours a week. I was sleeping in my car the last day before 10-K sign-off it was ridiculous. My PML at that firm didn't have the courtesy to even meet me face to face back them and frankly I was treated like human garbage by every team I worked for so it was no difficult decision to leave them. End result, the OPM said nothing substantive had changed his opinion for signoff and said “sorry” but not sorry to me.

    PwC, who I worked for 6 months after leaving KPMG absolutely disgruntled about my public accounting experienced signed hours off on ALL areas but planning. BLESS their heart. PwC and the engagement team I worked for one busy season there as a seasonal RESTORED MY FAITH in public accounting and humanity honestly. It blows my mind how standoffish KPMG was about the situation and how easy my PwC counterparts said “no problem”, “we got you bro”.

    Unfortunately this whole situation has turned my life plans upside down and I decided against going to QC. The KPMG OPM and my old solo practice boss should be THANKING me for instead seeking an alternative instead of appealing to QC. I ended up going back to public accounting to a top 25 as an audit manager without attest – who will have to make up those hours but that's fine.

    It was my dream to go into solo practice and I had a very distinct business strategy plan that aligned with the job that I had to quit to back pedal and earn hours.

    Nevertheless I do not harbor excessive animosity towards my old bosses. They probably are doing me a favor because gaining experience at the manager level for a smaller firm falls exactly better in line with someday going into solo practice and I have all the intention now since I'm making this pivot to stay as long as I can on the partner track until conditions tell me to go back to my original plan.

    It has been a frustrating personal experience. I have networked with probably 20-30 other CPAs in my region without much success for “moonlighting” audit or review side work which made me give up and just go back to public.

    However the bright side is I think I'm in a great firm with a good job and I had done so much ground level work on networking which lays a fantastic foundation for business development for future firm business.

    I make lemonade out of lemons.

    My two cents to anyone out there is don't quit until you get the signatures on your certificate of attest. Your old bosses are perfectly able to stiff you on attest hours because there is no professional duty to do anything other than fill out the form and respond. They can flat out deny you on the form and call it a day. QC for me was a last resort I didn't want to bother with, nor did I think it was in my best to piss of a Big 4 OPM and my old boss.

    I still think they should thank me for taking the high road and being a gentleman even if I am here anonymously complaining on a CPA Exam forum to vent.

    I hope my experience is helpful to anyone else who is thinking of getting attest signoff for their CPA…. get it done before you quit.

    AUD - 85
    BEC - 85
    FAR - 76
    REG - 75
    FAR  - 67, 47, 60, 76
    REG - 55, 56, 75
    AUD - 59, 73, 85
    BEC - 63, 74, 85

    Ethics - 92

    #2193463
    lurking_CPA
    Participant

    Heather – I did see you let your license lapse – i'm sorry about that. My buddy in CA got out of the profession too and let his lapse – I told him it was incredibly stupid because you never know where you're gonna be in 20 years or if you will need it. Fast forward 10 years he still is okay and thinks he doesn't need it *shrug* its his life man… anyway, It might also be easier if you can get the Washington board to send files to the California board with your hours than repeating the process again – did you call them to ask what they might have on file? For me, I just personally knew the admin in charge of CPA hours for our area. You might have to call your Washington office and figure out who the office managing partner is and their admin. Usually the office managing partner and your supervisor if they are a licensed CPA will sign off your hours. You're in a very difficult situation because KPMG was super heavy paper based 20 years ago and I don't know how much of your records are even in their system. My time at KPMG they had just about 99% transitioned to full eAudit and computer systems. I had just a handful of review jobs that I did on paper still I think because the clients just were old school like that. Good luck…

    AUD - 85
    BEC - 85
    FAR - 76
    REG - 75
    FAR  - 67, 47, 60, 76
    REG - 55, 56, 75
    AUD - 59, 73, 85
    BEC - 63, 74, 85

    Ethics - 92

    #2859615
    taxwave8, EA, CPA
    Participant

    Is there anyway to get signed off the certificate of attest experience in California?
    I've been performing audits for the last 20 years and the firm I work for refuses to sign off unless I buy into the firm.
    I'm also a CPA in two other states with full rights.

    #2859750
    freecloud
    Participant

    OMG finally someone has asked a question that I want to ask for a little bit long time.

    I am sorry I dont have any good advices to you, but will follow up your post with how to end up eventually.

    I am currently in California and always get confused for how to get work experiences in order to fully licensed as a CPA.

    Now I haven't done my all parts of exam yet, but I am tax accountant. There are two types of CPA license in California. I know I will get a license with one year general accounting and tax experience. But my goal is getting fully license for accounting, tax and audit.

    As a tax accountant at CPA firm which especially focus on tax preparation, planning and advisory services, but no that much audit work getting involved. How to get those 500 auditing hours in California?

    Have good faith in yourself on the way of studying CPA exams😄
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