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Public Accounting Firm
Registration Requirements

Business Organization: Any form of business organization authorized by law, including but not limited to a proprietorship, partnership, corporation, limited liability company, limited liability partnership or professional corporation. 

 

Every business organization of CPAs and PAs located in Oregon is required to register as a firm if the business organization meets any of the following conditions:

1) Uses the terms certified public accountant or public accountant, or their abbreviations,

2) Holds out to clients or the public that it is engaged in the practice of public accountancy, or

3) Performs attest or compilation services.

4)  

A permit holder doing business as a sole proprietor is required to register as a firm if the permit holder meets either of the following conditions:

1) Holds out to clients or the public as a business organization composed of more than one licensee, or

2) Performs attest or compilation services.

Registration is required if a business organization organized for the practice of public accountancy is:

- Located in Oregon, and

- Uses the terms "certified public accountant", "CPA", "Public Accountant", or "PA", or any derivation of such terms.

- Holds out to clients or to the publi that the business is in any way engaged in the practice of public accountancy; or

- Performs attestation or compilation services.

 

If the business organization is not located in Oregon, they firm must register with the Oregon Board of Accountancy if:

- Performs or offers to perform the following work in Oregon or for Oregon clients:

- Audit or other engagement for which performance standards are included in Statements on Auditing Standard (SAS), Examination of prospective financial information for which performance standards are included in the Statement on Standards for Attestation Engagements (SSAE) or engagements for which performance standards are included in the auditing standards of Public Company Accounting OVersight Board (PCAOB)

- Has a person, who is a license holder under ORS 673.150 or meets the substantial equivalency requirements of ORS 673.153, that is responsible for supervising attestation services and signs or authorizes someone to sign the accountant's report on the financial statements on behalf of the business organization.


 

  
 
Every permit holder who is performing public accountancy services as a business organization or under an assumed business name is required to register with the Secretary of State Corporations Division (503-986-2200). A date-stamped copy of the Corporation Division registration must be submitted with the application.
 
Firm names must comply with the requirements of OAR 801-030-0020. Firms with non-CPA/PA ownership must comply with the requirements of ORS 673.160 and OAR 801-010-0340.
 
Licensees may not practice public accountancy or hold out using the firm name until the licensee receives confirmation of the firm registration from the Board.
 
Firm registrations expire December 31 of each odd-numbered year.
 
Licensees who would like to register a firm must submit an Initial Firm Registration application. Initial Firm Registration Application

Firm Name Rules

OAR 801-030-0020 (6) prohibits the use of any firm name that is misleading as to the organization of the firm, nature of the services provided, the number of licensees associated with or working for the firm or the indentity of individual members of the firm.  

If the firm name includes the names of non-licensee owners, no form of the CPA/PA designation may be used in the firm name. If the firm name is composed of one or more past partners, shareholders, owners or members of the business organization or its successor, the past partner, shareholder, owner or member must not be actively engaged in the practice of public accountancy as a sole proprietor in the same market area, and they must approve, in writing, the continued use of such name.  Approval gien by a licensee for the contiued use of the licensee's name may be withdrawn by the licensee, in writing, and shall allow a reasonable period of teime for the firm to withdraw such name.
 
The letterhead and business cards may include the CPA/PA designation after the name of each CPA/PA. Other designations held by non-CPA/PA members may also be used on letterhead or business cards.
 
The following examples may be helpful in determining the firm name for a public accounting firm that includes non-licensee owners. In these examples, Jones is a CPA or a PA and Smith is an MBA: 
 

  "Jones & Smith, LLC" is ok
BUT:
  "Jones & Smith, LLC"
          CPA firm (not a part of title, but written below)      is not ok
  "Jones, CPA, & Smith, LLC" is not ok
  "Jones & Smith, Certified Public Accountant" is not ok

Branch Office
Every branch office located in this state shall be managed by a licensee holding a permit issued under ORS 673.150 who shall be in residence at the branch office, on a full-time basis, during the time the branch office is open to the public. A licensee operating a branch office is responsible for managing the office, staff and services rendered to the public.

Non-CPA Ownership
Applicable Statutes and Administrative Rules
ORS 673.160
OAR 801-010-0340
OAR 801-010-0345
OAR 801-030-0020 (6)
 
ORS 673.160(4) allows CPA/PA firms in the practice of public accountancy to include non-CPAs or non-PAs as owners.
 
OAR 801-010-0340 and OAR 801-010-0345 address requirements for Oregon public accounting firms and should be reviewed in their entirety on the BOA website. This information is an outline of the provisions for non-licensee ownership of public accounting firms, but is not a comprehensive review of the requirements. OAR 801-030-0020(6) regarding firm names should also be reviewed.
 
Ownership and Management
  1. A simple majority of the ownership of a public accounting firm must be held by licensed CPAs or PAs; non-licensees may own no more than 49% of the equity capital and/or voting rights. If the firm's principal place of business is in Oregon and public accounting services are provided in Oregon, a majority of the CPA or PA owners must be Oregon licensees (ORS 673.160).
  2. Non-CPA/PA owners of the firm may not hold out as CPAs or PAs.
  3. The person who is responsible for supervising attestation or compilation services and who signs financial statements must be an Oregon licensee.