Does a fractional CFO need to be a CPA?

The license and the job are different things. State accountancy laws reserve a short list of work for licensed CPAs, and Texas is a clean example. Only a license holder may issue a report on another person's financial statements or perform an attest service such as an audit or review, and nobody else may use the title "certified public accountant" or "CPA". The same statute says it does not stop non-licensees from providing management advisory services or preparing financial statements without issuing a report. Forecasts, budgets, KPI dashboards and cash plans sit on that side of the line. Your state has its own accountancy act, so check it; Texas is our example here, not a national rule.

Tax has a separate rule set. Any tax professional with an IRS preparer tax identification number (PTIN) may prepare federal returns for pay. Representation is tiered: enrolled agents, CPAs and attorneys have unlimited rights and can handle audits, payment and collection issues and appeals, while other preparers have limited rights or none. That is the practical reason to keep a CPA or enrolled agent on the tax side even when your CFO is neither.

The CFO role itself has no licensing requirement. The Bureau of Labor Statistics says financial managers typically need a bachelor's degree and 5 years or more of experience in another business or financial occupation, and that professional certification is not required. Credentials still tell you something. A CPA license signals depth in accounting and tax. The CFA charter is an investment analysis credential: three exams, about 300 hours of recommended study per level, and at least 4,000 hours of relevant work experience over no fewer than 36 months. Neither tells you whether someone can read a payer mix or model a second location.

We say this plainly because it applies to us. Stan Sukhinin is a CFA charterholder with 19 years in corporate finance, including UniCredit and Société Générale, and he is not a CPA. Sorso is not a CPA firm: we run the monthly books and the fractional CFO work, and we partner with licensed CPAs for tax filings and attest work. When you interview any fractional CFO, ask who files your return, who would sign reviewed or audited statements if a lender asked for them, and how the handoff at year end works. Get those answers before you sign.