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Board approves settlements for two firms tied to missing firm permits; members call for better outreach
Summary
The board approved settlement agreements with Jennifer Kilgore (settlement fee $3,500) and Carol Dubs ($2,000) for operating CPA firms in Connecticut without firm permits. Members urged improved notification and coordination with the Secretary of State; DCP staff said outreach and publications are underway.
The State Board of Accountancy approved two settlement agreements with licensees who the department says operated CPA firms without required firm permits.
Paul Grabowski, filling in for regulatory staff, presented the first case: Jennifer Kilgore (case 22 24Dash26), alleged to have operated JLK CPA LLC in Fairfield without a firm permit. The department says Kilgore was first licensed in 1997, formed the firm in 2017, was notified on April 23, 2024, and did not obtain a firm permit until Jan. 21, 2026. The parties agreed to a $3,500 settlement fee. The board voted to approve the agreement.
Grabowski then presented a second case, Carol Dubs (case 2026Dash19), involving Arbor Accounting LLC in Norwalk. Staff said Dubs worked part time and did not realize a firm permit was required; she was notified in January 2025 and promptly obtained a firm permit on Jan. 6, 2025. The department recommended, and the respondent agreed to, a $2,000 settlement fee; the board approved the agreement.
Several board members pressed staff on whether notification and onboarding procedures were sufficient. One member said the frequency of similar cases suggests “a structural information gap” and suggested improving notification when businesses register. Another board member said, “I just can’t support a penalty for not knowing,” arguing the state should provide clearer, earlier notice. Grabowski said the department’s enforcement position is that the respondents were out of compliance with the law, but staff are open to improving touch points and coordination with the Secretary of State.
Tiffany, speaking for the Department, said the Consumer Protection Department (DCP) has been increasing publications and outreach about firm-permit requirements and has done presentations; she said staff are seeking more collaboration with the Secretary of State to generate automated notifications when an LLC registers in a relevant category.
Separately, staff told the board they had initiated a 3% random CPE audit (133 credential holders) and that 99 responded; staff are contacting the remaining 34 and expect paralegals to begin reviewing submissions and that some enforcement actions may follow.
The board adopted both settlement agreements and directed staff to continue outreach and to follow up on coordination with the Secretary of State. No further disciplinary action was announced at the meeting.
