Client Trust Account Protection Program

Lawyers have statutory and ethical obligations to safeguard funds they hold in trust for their clients or other persons. Lawyers must keep those funds separate from their business and personal accounts. Lawyers must maintain accurate books and report timely and completely to their client regarding the status and accounting of these funds.

To strengthen public protection and better support attorneys in fulfilling their client trust accounting duties, the State Bar is implementing a Client Trust Account Protection Program.

With very few exceptions, all California lawyers must comply with new requirements to:

  • Register their client trust accounts (including IOLTA) annually with the State Bar, either individually or through their law firm or organization;
  • Complete an annual self-assessment of client trust account management practices (questions previewed here); and 
  • Certify with the State Bar that they understand and comply with requirements and prohibitions applicable to the safekeeping of funds and property of clients and other persons in rule 1.15 of the Rules of Professional Conduct.

Beginning in December 2022, attorneys will be able to fulfill their reporting requirements through My State Bar Profile; law firms and organizations will be able to provide account information for attorneys through agency billing. To register a CTA, including IOLTA, you will need to report the year-end balance on December 31 of the reporting period. You should use the bank balance on that date (i.e., the balance including only cleared transactions).

For 2023, the State Bar will not impose penalties for failure to comply with CTAPP requirements until after April 3. Penalties for other requirements will still be imposed in February. You can pay licensing fees and report MCLE compliance before completing your CTAPP reporting obligations. In future years, pursuant to rule 2.5 of the Rules of the State Bar, the CTAPP reporting deadline will be February 1.

Later phases of the CTAPP will involve further enhancements, including:

  • Expanded public outreach and education on the rights of clients and attorney responsibilities;
  • Enhanced education for attorneys on best practices in client trust account management; and
  • Compliance reviews of selected lawyers by a certified public accountant to ensure adherence to client trust account management requirements.

Watch this video for a brief overview of the CTAPP.