Does your firm have up-to-date succession plans? SCACPA and the South Carolina Board of Accountancy are partnering to remind CPAs that this year’s firm renewal process will address this question as new regulations are in effect. The purpose is that there is an accounting for custody of client records.

Renewals are set to open on the evening of Monday, Nov. 30. On your renewal, the question will look like this:

“Regulation 1-12(a) states that ‘Each licensee or firm that has custody or ownership of client records shall designate a partner, personal representative, or other responsible party to assume responsibility for client records in the case of incapacity or death of the licensee or dissolution of the firm.’

“Do you have custody or ownership of client records?” [Yes/No] 

If Yes:

a) Do you have a succession plan? [Yes/No]

b) Please list the name and phone number of the individual, CPA, or firm you have designated as the responsible party in your succession plan: [text box to enter information]

Here is a small screengrab of what the questions look like:

On the online renewal form, the question is broken out so that if they answer yes to the ownership/custody of client records question, it will take you to the succession plan questions. If the answer is no to the custody/ownership of client records question, the process moves on to the next item. Here is a small screengrab of what that will look like:

In addition, the BOA has previously shared links to two publications that address succession planning:

“Practice Continuation Agreements: A Practice Survival Kit” (AICPA/NASBA, 5-page document):

“Practice Continuation Agreements: A Practice Survival Kit” (AICPA online publication):

Any licensees who have questions should contact BOA staff at 803.896.4770 or