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CBA committee preserves broad general experience standard, clarifies attest job tasks and allows non‑employment qualifying settings
Summary
Committee approved three staff recommendations: defer specifying job tasks for general accounting experience (but increase the time requirement to two years), express attest requirements explicitly as job tasks, and clarify that qualifying experience may be gained outside employment, including internships, contracts and supervised volunteer work.
The Committee on Professional Conduct on May 15 adopted staff recommendations clarifying how qualifying accounting experience will be documented under AB 11 75 and related regulatory drafting.
Staff delineated three experience components: the work performed, the setting in which it is performed, and the supervision accompanying it. For general accounting experience, staff recommended deferring a decision on enumerating specific job tasks and instead increasing the minimum general accounting experience from one year to two years; that change would be the only substantive change to general experience at this stage. For attest (test) experience, staff recommended modifying the existing regulations to express the four or five currently required attest functions as explicit "job tasks," aligning regulatory language with AB 11 75 without increasing the underlying requirement (including the 500‑hour minimum for attest functions documented by a supervising CPA). Finally, staff recommended clarifying that qualifying experience need not be obtained solely through employment and that internships, contracts and supervised volunteer work (for example, VITA volunteer tax assistance supervised by a CPA) may qualify when adequate supervision and documentation exist.
Committee members queried how volunteer settings would provide appropriate breadth of experience beyond tax work; staff and a committee member noted that general experience does not require a cross‑section of accounting activities and that candidates could meet the requirement solely through tax work if supervised work and documentation satisfy standards. Staff emphasized that externships, where work is not performed, would not qualify.
The committee voted to adopt the three staff policy directions. The motion passed on roll call with all members present voting yes: Doug Aguilera; Nancy Corrigan; Carrie Ann Ferrell Hines; Christian Latta; Tony Lin; and Pinyan Tu.
Next steps: staff will draft regulatory text that increases the general experience time requirement, formalizes attest job tasks language, and adds clarifying language about acceptable non‑employment settings for qualifying experience.
