In support of the mission to “support... efforts for greater access, and inclusion in, the legal system,” the State Bar aims to encourage and incentivize legal employers to take action to advance diversity, equity, and inclusion in their organizations. Similarly, promoting diversity and inclusion in the legal system is a key priority of the State Bar’s 2022–2027 Strategic Plan. A more diverse, accessible, and inclusive legal workplace improves the experience of employees and their clients. A legal profession that better reflects the diversity of California’s communities can improve public access to, and fair treatment in, the legal system.

The CTAPP reporting deadline is the same as the licensee’s deadline for paying their license fees (Rule 2.5(C) of the Rules of the State Bar). The annual renewal cycle deadline is March 30. This is also the deadline for other requirements (e.g., MCLE compliance, etc.). (Rule 2.11 of the Rules of the State Bar.) For new attorneys, the deadline is 45 days from the invoice date for their fees (Rule 2.12 of the Rules of the State Bar).

If a lawyer is a signatory on a trust account, exercises managerial or primary administrative oversight for a trust account, or is otherwise responsible for complying with any of the requirements or prohibitions in rule 1.15 of the Rules of Professional Conduct—other than the disclosure and agreement requirements in rule 1.15(b) pertaining to depositing a flat fee paid in advance into a lawyer’s or law firm’s operating account—the lawyer is responsible for those funds. The lawyer remains responsible even if other lawyers are also responsible for the safekeeping of funds. The lawyer is ultimately responsible even if nonlawyers are assigned certain accounting tasks for those funds; for example, bookkeeping and banking related to client trust accounts. (See Rules Prof. Conduct, rule 5.3.)

Accounting and recordkeeping activities are only one part of a lawyer’s duties to properly handle entrusted funds. Other duties include, for example, the responsibility for giving notice to the client or other person that funds were received on behalf of the client or other person and identifying and resolving disputes about entitlement to trust funds. These duties ordinarily are not the job of a firm’s bookkeeper. All of these responsibilities are considered nondelegable duties. The proactive regulation, reporting, and monitoring of CTAPP are intended to promote a lawyer’s compliance and prevent avoidable financial harm to clients. The only aspect of CTAPP reporting that can be fulfilled by the lawyer’s firm is the annual registration of client trust accounts by a firm or organization that is registered with the State Bar’s Agency Billing platform.

A licensee is “responsible for client funds and funds entrusted by others under the provisions of rule 1.15 of the Rules of Professional Conduct” within the meaning of this rule if, at any point during the reporting period, they acted as a signatory on a trust account—even if there was no money in the account, exercised managerial or primary administrative oversight for a trust account, or were otherwise responsible for complying with any of the requirements or prohibitions in rule 1.15 of the Rules of Professional Conduct—other than the disclosure and agreement requirements in rule 1.15(b) pertaining to depositing a flat fee paid in advance into a lawyer’s or law firm’s operating account. The requirements and prohibitions in rule 1.15 are not limited to banking and recordkeeping duties and include, for example, the responsibility for giving notice to the client or other person that funds were received on behalf of the client or other person and the duty to identify and discharge liens.

Lawyers who were responsible for entrusted funds in the reporting period must also register, or have their firm register through the State Bar’s Agency Billing application, all client trust accounts, take a self-assessment of client trust account management practices, and certify their compliance with requirements of rule 1.15 of the Rules of Professional Conduct.

If you need to disassociate a client trust account that is no longer active or held by a firm by which you are no longer employed or in practice with, you should:

1. Log in to your My State Bar Profile.
2. Navigate to the CTAPP reporting section.
3. Locate the account you wish to disassociate in your list of accounts.
4. Click on the plus sign (+) on the right-hand side of the screen to expand options.
5. Select the “Update Connection” tab on the account details pop-up.
6. Change the “Connection to Attorney” to “Disassociated/Added in Error.”
7. You will need to provide a disassociation reason and a disassociation effective date.
8. If you are reporting a disassociation effective date more than 30 days after the disassociation date, the system will prompt you for a reason why you are reporting it after the 30-day update deadline. At this time, there is no penalty for noncompliance with the 30-day update requirement. Answering this question truthfully will not result in an increased likelihood of a CTAPP compliance review or investigatory audit. The State Bar’s current focus is on gathering accurate information, educating licensees about their trust account responsibilities (including the 30-day update requirement), and improving overall compliance. There is a 50-character limit on this field.
9. Click the “Save” button.

This process removes the account from your profile for future reporting periods but maintains the historical record as required.

In general, under rule 1.15(a) of the Rules of Professional Conduct, a licensee’s trust accounts must be maintained in California, or, with the written consent of the client, in another jurisdiction where there is a substantial relationship between the client or the client’s business and that other jurisdiction. Therefore, if licensees are entitled to hold IOLTA accounts outside of California, they will need to register those accounts as non-CA IOLTA accounts by selecting “Add Account” in My State Bar Profile, or, if using the Agency Billing application, selecting “Manage Accounts.”

Pro bono opportunities vary depending on the needs of the client community. Examples of pro bono legal services to indigent clients may include, but are not limited to: 

• Representation (full or limited scope)
• Negotiation and settlement
• Screening and intake
• Brief service by phone or in person
• Legal information or “Know Your Rights” workshops
• Document preparation and review
• Legal research and writing
• Litigation support
• Legislative research and legal analysis

Depending on the type of screen you are on when you exit, the course will resume at that point or at the beginning of the same section. However, if this is not the case, your device may be referring to an earlier memory cache (version) of the course and may not be refreshing correctly. Try carrying out each of these options until you resolve the issue: 

1. Clear your browser’s memory cache/history
2. Try using a different Internet browser. The following are optimal: Windows 7/10: Google Chrome, Internet Explorer 11 or above; iOS Safari
3. Try launching the course on a different device.

Attorneys who are eligible for fee scaling and agree to comply with all required obligations by the April 1, 2025, including: 

• Attorney profile verification
• Client Trust Account Protection Program
• MCLE compliance (if applicable) I

f an attorney is assessed a noncompliance penalty for any required annual reporting obligation, they will no longer be eligible for the installment plan and must pay all outstanding fees and costs in full by June 30, 2025.

Yes, attorneys may pay their installments in advance if they wish to complete their payments before the final deadline of October 1, 2025.