May 04, 2012

Disciplinary Investigations Don’t Relieve You from Protective Responsibilities

By Mike Colgan, PICPA Executive Director and CEO

While following up on several recent disciplinary actions by the State Board of Accountancy and requesting copies of Consent Agreements from the Department of State Prothonotary, I made a shocking discovery. Attached to some of those Consent Agreements were copies of confidential client information that had been submitted by the licensees during the course of the investigation. These documents, primarily client tax returns, included client names and Social Security numbers. I asked Jeff McGuire, PICPA’s legal counsel, to review the situation. You can read his response here.

We contacted the State Board of Accountancy and the prosecutor’s office at the Department of State, and learned that these documents were posted by the prosecutor. We have since talked to the prosecutorial office staff to be sure that they redact all personal information in the future. That said, PICPA members are advised that when cooperating with an investigator from the Department of State and client documents are requested, make sure all personal client information is redacted from those documents before submission.

The PICPA regularly attends State Board of Accountancy meetings. If you have any questions or concerns regarding issues related to the State Board, please feel free to contact me at mcolgan@picpa.org or (215) 972-6181. The next meeting is May 15th.

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Statements of fact and opinion are the authors’ responsibility alone and do not imply an opinion on the part of PICPA officers or members. The information contained in herein does not constitute accounting, legal, or professional advice. For professional advice, please engage or consult a qualified professional.