FSBA

 

 


 

Facilitated State Board Access (FSBA)

Click on each question below to show or hide the answers. 

 

What is FSBA?

FSBA is a process that the American Institute of CPAs (AICPA) created to help keep up with the evolving changes in the business and regulatory environments and to address the demand for greater peer review transparency.

How does my firm benefit from the FSBA process?

This process is intended to create a nationally uniform system through which CPA firms can satisfy state board or licensing body peer review submission requirements, increase transparency, and retain control over their peer review results. The AICPA and state CPA societies are working together to allow this process to become the primary means by which all state boards of accountancy (BOAs) obtain peer review results. This process will make submission of your firm's peer review information easier. Read Connecticut's peer review information submission requirements.

Will my firm's peer review information be made public as well as a result of this process?

No, a firm's peer review information will not be made available to the public as a result of this process. A firm's peer review results will be posted to a secure BOA website that will only be available to authorized state board representatives. However, many firms already make their peer review results available as part of their AICPA membership or Government Accountability Office (GAO) or BOA requirement. In addition, many firms make their peer review results available upon client request as it demonstrates a firm's commitment to quality.

Will my firm's peer review information that is posted to the secure BOA website be shared with others?

That is not the intent of this process; however, each BOA's statutes and regulations govern this matter. In addition, due to the Freedom of Information Act (FOIA) legislation that applies in some instances, BOAs may share information with others once they have obtained it.

How does this affect my firm's peer review information submission requirements?

Beginning in 2015 the Connecticut State Board of Accountancy will accept an electronic notification and submission of your firm's peer review report and acceptance letter.

When will FSBA be implemented?

FSBA has been nationally implemented with full participation by all 50 states.

How does the FSBA process work?

FSBA uses an opt-out process that allows peer review results to be made available to select BOAs on a voluntary firm basis, using a secure, BOA website that will only be available to authorized state board representatives.  For firms whose main office is located in Connecticut,  the CTCPA will notify the firm when their peer review information is posted to the secure BOA website.  Firms that are not members of the AICPA Employee Benefit Plan Audit Quality Center (EBPAQC), Governmental Audit Quality Center (GAQC), or Private Companies Practice Section (PCPS) will be given an opportunity to opt out of the process.  Below are the details of how the new process will work.

In Connecticut
, the process will entail:

  • Making peer review results available to select BOAs on a voluntary firm basis, using a secure, BOA website that will be available only to authorized state board representatives.  The CTCPA will post applicable peer review information related to a firm’s most recently accepted review to this secure BOA web site unless the firm requests that its information be excluded.  The firm will be notified by the CTCPA, via a notice included with the firm’s peer review acceptance letter of its intention to post the firm’s peer review results and the firm will have 30 days to opt out of the process.

  • Once the CTCPA posts the information, the firm’s managing partner and peer review contact will receive a confirmation via email (or regular mail if email is not available) informing them that the results have been posted to the site and a reminder that the firm has 30 days from the date of the acceptance letter to opt-out of the process.  The email also provides the partner and peer review contact the opportunity to make the firm’s results available to additional select BOAs.

  • After 30 days, if the firm does not opt out, the firm’s peer review results will be available to authorized BOA representatives via a secure BOA web site.  It is anticipated that this option will be beneficial, over time, to firms with multi-state practices.  

Firms can request that their results be made available to more than one BOA, as long as the BOAs require peer review and are not prohibited from obtaining access to peer review information. 

When can I expand access to other BOAs outside of those currently participating?

Firms will be provided with an opportunity to select additional BOAs to receive expanded access on the peer review scheduling form and again once the peer review results are posted.

What peer review information will be posted by the CTCPA to the secure BOA website for firms that do not opt out?

The following documents will be posted, as applicable, to the secure BOA website.  The number of documents posted for each firm can vary based upon the results of the peer review.  It is important to note that unless a firms opts out, all applicable documents will be posted even if it is not a state requirement.  A firm that does not opt out will not choose which documents to post as each of those applicable (based on the results of its peer review) will be posted.

  • Peer review report
  • Letter of response
  • Acceptance letter
  • Letter(s) signed by the reviewed firm indicating that the peer review documents have been accepted with the understanding that the reviewed firm agrees to take certain actions
  • Letter notifying the reviewed firm or individual that certain required actions have been completed. 

What if my firm changes its mind and wants to opt out after the information has been posted?

A firm that is not a member of the AICPA Employee Benefit Audit Quality Center (EBPAQC), Governmental Audit Quality Center (GAQC) or Private Companies Practice Section (PCPS) may opt out at any time by notifying the CTCPA in writing.  Once the CTCPA has been notified, the information will be removed from the website.  However, certain information (which is currently publicly available) will remain posted to the secure BOA website.

What if my firm is required to sign its acceptance letter agreeing to take certain actions (as a condition of peer review acceptance) and 30 days have elapsed from the date of the opt-out letter, but my firm has not returned the signed acceptance letter to the CTCPA?

There may be situations where a time lapse occurs between the CTCPA receiving the signed acceptance letter and the 30 days to opt out.  The CTCPA will not post the firm's peer review information to the secure BOA website unless it has received the signed acceptance letter because a review is not considered accepted until the firm agrees in writing to take the actions required.  For such firms that ultimately elect not to opt out, the peer review information would be posted the later of 30 days after the date the acceptance letter or the date the acceptance letter is signed by the firm.

Isn't this an example of how rules imposed on large firms can cascade down to small firms?

No.  There is growing demand for increased transparency in all facets of business; this demand is driven by marketplace and regulatory trends that affect firms of all sizes.  Currently, 52 out of 54 SBOAs either mandate peer review as a condition of licensure and many of those states already require some fort of submission of peer review information as a condition for renewal of a license.

What happens if my firm already allows its peer results to be posted to the existing public files as a condition of membership in the Governmental Audit Quality Center (GAQC), Employee Benefit Plan Audit Quality Center (EBPAQC), or Private Companies Practice Section (PCPS)?

Because the information is already in the public file as a condition of membership, your firm will automatically have its peer review results posted to the secure BOA website.  Your firm will not be able to opt out from providing access to the Connecticut BOA but will receive a letter from the CTCPA informing you that your peer review results have been posted to the secure BOA website and giving you the opportunity to make your peer review results available to other BOAs.  If you request the CTCPA to do so, it will grant access to the authorized state board representatives in the state(s) you specify.

Whom do I contact if I have questions?

You can contact Bonnie Olivieri at 860-258-0213 or bonnieo@ctcpas.org