So they're not very clear about it on the AICPA website and when I called there were not very well-informed either. But here is ONE of the criteria for qualification if you're already a licensed cpa.
Three years of financial (including internal audit) or management accounting experience in business, industry, or government
Question is: if you served as a Financial analyst role for a relatively small company of about 45 to 50 employees (no licensed cpa) does that count?