Federal Law (FCRA)
The Fair Credit Reporting Act (FCRA) establishes the federal minimum requirements for employment background checks, including disclosure and authorization requirements, consumer rights, and the adverse action process. Many states impose additional requirements that employers must also follow.
Read FCRA OverviewRecommended Screening Components
The components below reflect common elements of an accounting screening package. Requirements change based on the funds the role can reach and whether it carries a professional license.
| Screening Component | What It Covers | Recommendation |
|---|---|---|
| Names and addresses associated with the applicant, which identify where to search. | ||
| Criminal records in the counties where the applicant has lived and worked. | ||
| Broad multi-state coverage that points toward records a county search would miss. | ||
| Federal court records, where wire fraud, tax evasion, and embezzlement cases are filed. | ||
| Past employers, dates, and titles, which establish the scope of prior financial responsibility. | ||
| Degree awarded, date, and field of study, confirmed through the issuing institution. | ||
| Payment history, collections, and public records. Restricted by law in several states. | ||
| CPA license status and board discipline, or certification standing. Licensed roles only. | ||
| Judgments, liens, and civil suits filed against the applicant in county courts. | ||
| Sanctions and enforcement lists, relevant where the role moves money across borders. |
Screening components should always be job-related and consistent with applicable federal, state, and local laws.
Notes on This Package
Financial offenses are prosecuted in federal court. Wire fraud, tax evasion, and embezzlement crossing state lines are federal cases, filed in a separate court system that county and state searches do not reach. Accounting is one of the few positions where a federal criminal search belongs in the standard package rather than as an addition.
Segregation of duties changes the exposure. In a large finance department, no one person records a transaction, approves it, and reconciles the account. In a small organization one bookkeeper often does all three, which removes the control that would otherwise catch an error or a diversion. The screening depth usually follows that, not the job title.
Titles are inconsistent across employers. Bookkeeper, accountant, accounting manager, and controller mean different things at different companies, and none is a protected term. Employment verification confirming dates and titles says less here than a conversation about what the person actually had authority to do.
Certifications carry renewal requirements. A CPA license, a management accounting certification, and an internal audit credential each have continuing education requirements and lapse without them. A credential earned years ago may be inactive, and the issuing body is the only place that shows.
Credit Reports in Accounting Roles
Accounting is where credit reports are ordered most often and restricted most often. Both are worth understanding before the package is built.
What an employment credit report shows
It lists payment history, accounts in collection, and public records such as bankruptcies. It does not include a credit score, since employment versions omit it. It also does not show income, savings, or current account balances, which is why it answers less about financial stability than employers often expect.
Where state law restricts it
Several states prohibit employers from using credit reports in hiring, with exceptions that vary by state. The common exceptions cover positions with fiduciary responsibility, access to funds above a stated amount, or financial institution employment. The exception attaches to the duties of the position rather than to its title, so a role called controller does not qualify automatically. Check the State Laws Overview for the states where you hire.
What the report supports
A credit report shows financial pressure, which is one factor in evaluating a role with access to funds. It does not show dishonesty, and adverse entries frequently trace to medical debt, divorce, or job loss. Where a report contributes to a decision, the FCRA adverse action process applies, including the opportunity to respond before the decision becomes final.
Where Screening Changes
The same job title carries different requirements depending on the setting.
| Financial Services | Federal law bars people convicted of dishonesty offenses from working at insured institutions, and registered roles add fingerprinting and regulatory disclosure. |
| Professional Services | Public accounting adds CPA board verification, independence disclosures, and client screening requirements for staff working on client sites. |
| Government | Public agency finance roles carry civil service rules, fingerprint checks, and public sector fair chance restrictions on criminal history use. |
| Nonprofit | A single bookkeeper often handles every step, and grant terms and insurers commonly set the screening requirement. |
| Healthcare | Billing and coding staff touch federal claims, which brings federal exclusion list checks into the package. |
| Retail | Store-level cash handling and reconciliation sit closer to loss prevention screening than to corporate finance. |
Screening Considerations
Access to Funds
What a role can initiate, approve, and reconcile determines the exposure. A clerk entering invoices and a controller with wire authority carry different risk, and screening depth commonly follows that rather than seniority.
Credit Report Restrictions
Several states limit employment credit checks and permit them only for positions meeting a defined exception. The exception is written around duties, so the analysis is about what the role does with money.
Federal Criminal Coverage
Financial crimes crossing state lines are prosecuted federally and filed in a separate court system. A package limited to county coverage will not reach them.
License and Certification Status
CPA licenses are verified through the state board, which also publishes disciplinary actions. A CPA licensed in several states carries a separate record in each, and certifications lapse when continuing education is not completed.
Employment Verification Depth
Titles vary widely between employers, so dates and titles alone say little about prior authority. Verification confirming reporting relationships and scope of responsibility carries more weight in this field.
Civil Judgments and Liens
Civil records are county-based and inconsistently indexed, and a filing reflects an allegation rather than a finding. Tax liens and judgments also appear on a credit report, so the two sources overlap.
Segregation of Duties
Small organizations concentrate recording, approval, and reconciliation in one role, which removes the control that would otherwise catch a problem. Screening is commonly deeper where that concentration exists.
Ongoing Requirements
Licenses lapse and discipline is entered during employment. Regulated employers and some insurers set a rescreening interval, and reports obtained after hire require their own disclosure and authorization.
Common Questions
Can we run credit on accounting staff?
In most states yes, and several restrict it to positions meeting a defined exception. The exception follows what the role does with money, not what it is called.
Does an employment credit report show a score?
No. Employment versions omit the score. They show payment history, collections, and public records such as bankruptcies.
Why add a federal criminal search?
Because wire fraud, tax evasion, and embezzlement crossing state lines are federal cases. County and state searches do not reach that court system.
Is every accountant a CPA?
No. Most accounting work requires no license, and CPA licensure is required only for specific services. There is no license to verify for unlicensed roles.
How is a CPA license verified?
Through the state board of accountancy, which shows current status and published discipline. A CPA licensed in several states has a separate record in each.
Does bad credit disqualify an applicant?
Not by itself, and several states limit its use entirely. Adverse entries often trace to medical debt, divorce, or job loss rather than to how someone handles money.
What does a bookkeeper title mean?
It varies by employer and is not a protected term. Verification of scope and reporting relationships says more than the title alone.
Do certifications expire?
Yes. CPA licenses and most accounting certifications carry continuing education requirements and lapse without them. Only the issuing body shows current standing.
Worth Knowing
Most Accountants Are Not CPAs
CPA licensure is required for specific services such as signing an audit report. Most accounting, bookkeeping, and controller work requires no license at all, so there is no board record to verify and no disciplinary history to search.