The State Bar’s Client Trust Account Protection Program (CTAPP) will implement compliance reviews of client trust accounting in 2025. The State Bar seeks public comment on the proposed scope of the compliance review procedures to be conducted by a certified public accountant.
Deadline: August 4, 2025, 11:59 p.m. (60 days)
Comments should be submitted using the online Public Comment Form. The online form allows you to input your comments directly.
Rule 9.8.5 State Bar Client Trust Account Protection Program (CTAPP), approved by the Supreme Court, effective January 1, 2023, requires the State Bar to establish and administer a CTAPP for the protection of client funds held in trust by a licensee that facilitates the State Bar’s detection and deterrence of client trust accounting misconduct. As part of CTAPP, the State Bar was given authority to impose compliance reviews of client trust accounting to be conducted by certified public accountants.
Rule 2.6 of the Rules of the State Bar sets forth the requirements for compliance reviews and provides for the confidentiality of records provided to the State Bar or its agents as part of the compliance review process. Compliance reviews will be completed by certified public accountants approved by the State Bar at the licensee’s expense. (Special provisions will be made for licensees with financial hardship.) During the compliance review, the accountant performs specific procedures and reports the findings without providing an opinion or conclusion.
Public comment is sought on the scope of the compliance review procedures. The proposed scope includes ensuring that licensees who hold funds and property on behalf of clients and other persons maintain accurate and complete records, that all transactions are in accordance with their client’s or other person’s documented expectations, and that the licensee fulfills their duties to communicate with clients and supervise their trust accounting practices as required by the Rules of Professional Conduct.
N/A
Division of Regulation
August 4, 2025, 11:59 p.m.