I work part-time at a government agency. Do I need to report?
Yes. Business and Professions Code section 6073.2(d)(2) only applies to full-time employees or officers or elected officials of the State of California, or political subdivision thereof, or the federal government. Part-time employees are required to report either the amount of pro bono service hours provided in the past year, that they did not track their pro bono or reduced fee legal services hours, that they did not complete any pro bono or reduced fee legal services hours, or that they decline to answer.
How do I make changes to the response I submitted?
Prior to the March 30, 2026, deadline, you can make changes to your pro bono hours reporting by going to My State Bar Profile, navigating to the Summary tab (located on the top navigation bar), and selecting “Edit your Pro Bono Hours” from the Pro Bono Hours tile (located about three-quarters of the way down the page).
Does the State Bar have a program for attorneys who only want to do pro bono work?
The State Bar’s Pro Bono Practice Program (PBPP) allows attorneys who would otherwise be inactive to maintain an active license, free of fees, to exclusively provide pro bono legal services in partnership with a pro bono legal services provider. To qualify for the PBPP, an attorney must maintain an active license, submit an application annually for the program, be certified as a pro bono practice attorney, and exclusively provide pro bono legal services through an approved or qualified pro bono services provider. For more information, see the Pro Bono Practice Program webpage.
How do I track and report my pro bono or reduced fee legal services hours?
Attorneys are expected to track their own hours for the purposes of this reporting requirement. Some law firms require their attorneys to track this time already. A nonprofit with whom the attorney provides pro bono legal services may assist in tracking hours.
Attorneys are asked to report pro bono and reduced fee hours as a range (e.g., 1–5 hours, 6–10 hours, 11–19 hours, etc.). Attorneys will also be able to select 0 hours or less than 1 hour of pro bono or reduced fee legal services hours, or select the checkbox if you did not track your hours or you prefer not to answer.
Does volunteering with an LRS oversight panel count as pro bono legal services?
Possibly. Uncompensated work with an LRS oversight panel may count toward the pro bono hours requirement if it enables the delivery of legal services at a charitable, religious, civic, community, governmental, or education organization in matters in furtherance of its organizational purposes as defined under Business and Professions Code section 6073.1(c)(1)(C). Licensees should use their best judgment when determining whether the work performed, particularly non-legal tasks, enables the direct provision of legal work to the indigent or other nonprofit organizations.
Does uncompensated work by volunteer attorneys at a legal aid organization or law school, or as a court mediator, count as pro bono legal services?
Yes. Uncompensated work by volunteer attorneys that enables the delivery of legal services at a charitable, religious, civic, community, governmental, or education organization in matters in furtherance of its organizational purposes would qualify as bono hours as defined under Business and Professions Code section 6073.1(c)(1)(C). This includes volunteer teaching at a law school as well as volunteer mediation or arbitration services provided through a court, even when the parties are not indigent.
Does serving on the board of a local or affinity bar association count as pro bono legal services?
It depends. Service to a local or affinity bar association counts toward the pro bono hours requirement if it is legal in nature (i.e., providing legal services to the nonprofit directly pursuant to Business and Professions Code section 6073.1(c)(1)(B) or 6073.1(c)(1)(C)). General board service qualifies only to the extent that the work enables legal services to the indigent, to another “charitable, religious, civic, community, governmental, or educational organization in matters that are designed primarily to address the needs of persons of limited means,” or to another “charitable, religious, civic, community, governmental, or educational organization in matters in furtherance of its organizational purposes.” Licensees should use their best good-faith judgment in determining whether their non-legal board activities enable the direct provision of legal work to the indigent or other nonprofits.
Does serving on the board of a legal aid organization count as pro bono legal services?
For purposes of this reporting requirement, board service for a legal aid nonprofit would qualify because all board work with such an organization is enabling the delivery of legal services to the indigent (since these organizations primarily serve indigent California residents). Please note that some legal aid providers and other nonprofits for which attorneys provide pro bono legal services may also ask attorneys to report pro bono hours, but the definition for pro bono legal services may vary for their purposes. Attorneys should confirm definitions with the entity before reporting pro bono hours to the entity.
What are some examples of pro bono legal services?
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
What is the guidance on pro bono and reduced fee hours reporting for pro bono professionals, law school professors, and attorneys employed at law schools?
Any active licensee who does not meet one of the exemptions in Business and Professions Code section 6073.2(d) is required to report the amount of pro bono service hours provided in the past year, including pro bono professionals, law school professors, and attorneys employed at law schools. Attorneys are asked to provide their best, good faith effort at reporting the amount of pro bono and/or reduced fee legal services hours provided to low-income individuals, nonprofit organizations, or public law libraries during the past year to meet the requirement of Business and Professions Code section 6073.2. Even licensees who are exempt from reporting their pro bono hours must declare their exemption status in My State Bar Profile.
My employer is already a seal recipient, but we have implemented more Action Items and want to move up to a higher tier. What are the next steps? What documentation is required?
DEI Leadership Seal recipients who want to advance tiers must complete and submit a DEI Leadership Seal Tier Advancement Application and supporting documentation. The State Bar will provide several opportunities throughout the year for seal recipients to submit this documentation and advance tiers. Seal recipients that want to advance tiers must still submit an attestation form to affirm implementation of the Action Items for which their materials have already been reviewed and approved.
2.2 Who is required to complete the CTAPP reporting requirements?
With very few exceptions (see FAQ 2.3 below), all licensees who held an active license status at ANY time during the reporting period must complete the CTAPP reporting requirements. For 2026, the reporting period is January 1–December 31, 2025. This includes those licensees whose status changed to voluntary inactive at any time during the reporting period.
2.10 I do not maintain my own trust account, but I work for a firm that has a trust account. How do I know if the firm trust account is maintained “on my behalf”?
Rule 1.15 requires attorneys who handle trust funds to hold those funds in one or more interest-bearing bank accounts labeled as a “Trust Account,” or words of similar import. If, at any point in the reporting period, you were responsible for complying with any of the requirements or prohibitions in rule 1.15—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—(e.g., responsibilities for the safekeeping of funds, identifying and discharging of liens, notifying clients that funds have been received, etc.), regardless of whether someone else ultimately performed this function, you are required to have a trust account. If the firm’s trust account(s) are available funds for the deposit of your client’s funds, then that trust account/those trust accounts are maintained, at least in part, on your behalf.
Therefore, if at any point in the reporting period, you were responsible for complying with any of the requirements or prohibitions in rule 1.15—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—you should answer, “Yes, a firm or organization I am currently employed by or in practice with …,” “Yes, however, I am no longer employed by or in practice with the firm or organization …,” or both to at least one of the questions in CTAPP Step 1 (Annual Client Trust Account Reporting) and thereafter complete the remaining CTAPP requirements. If your firm administrator will register the IOLTA and/or non-IOLTA account details on your behalf through the State Bar’s Agency Billing application, you may check the checkbox to indicate that in Step 2 (Account Registration).
If you have further questions about trust accounts, including whether you are responsible for complying with rule 1.15, whether you need a trust account, the rules of trust accounting, the recent changes to the rules regarding the safekeeping of funds, etc., please contact the State Bar’s Ethics Hotline research service at 800-238-4427 (toll-free in California). The Ethics Hotline cannot provide legal advice, nor tell you how to comply with any of the CTAPP requirements, including whether to answer “yes” or “no” in any portion of the CTAPP reporting requirements.
Do I need to provide proof of my financial situation to receive a settlement offer?
No, you don’t need to provide any financial documents to receive an offer to settle for less than what you owe. For attorneys not allowed to practice law as of January 1, 2025 and who cannot afford the settlement offer, the State Bar will ask for more information to determine if extreme financial hardship should be considered in accepting a lower settlement for collections purposes only.
What happens to my payment plan with FTB, or my garnishments through FTB, if I settle through the Fresh Start Settlement Program?
When you sign the Settlement Agreement, the State Bar will recall your debt from FTB within two weeks. Any payments already in transit from FTB to the State Bar at that time belong to the State Bar and will not be refunded to you.
Why were these debts not discharged in my bankruptcy proceeding?
Please email collections@calbar.ca.gov for information on how the outcome of your bankruptcy proceeding affected debt owed to the State Bar.
What types of employers are eligible to apply for the DEI Leadership Seal?
Employers, regardless of sector, that employ California-licensed attorneys are eligible to participate in the DEI Leadership Seal Program. This includes, but is not limited to, law firms of all sizes, in-house legal departments, legal academia, nonprofit organizations, and government agencies with attorney staff.
My employer is already a seal recipient. What documentation is required to remain in the program?
DEI Leadership Seal recipients must submit an annual attestation form to confirm that they continue to have at least five of the ten Action Items implemented. Current seal recipients must submit the DEI Leadership Seal Attestation form annually.
Is the State Bar, as an employer, participating in the program?
Yes. The State Bar earned the gold tier DEI Leadership Seal in January 2024. The State Bar recruited three impartial external reviewers to review and score the State Bar’s application and submitted materials.
2.1 What are a lawyer’s obligations regarding entrusted funds?
A lawyer in possession of client or third-party funds and property is a fiduciary. A lawyer must safeguard and segregate those funds and not commingle them with the lawyer's personal or business accounts. (See FAQ 1.3, above, for a description of the two types of trust accounts a lawyer may open to hold client or third-party funds.)
A lawyer must report timely and completely to their client regarding the status and accounting of client funds. A lawyer’s obligations regarding entrusted funds and property are set out in rule 1.15 of the Rules of Professional Conduct. In addition, under rule 1.4 of the Rules of Professional Conduct, a lawyer must keep their client reasonably informed about significant developments related to a client’s representation. Comment [1] to this rule specifies that a lawyer’s receipt of funds on behalf of a client ordinarily is a significant development requiring such communication with the client.
2.9 I have a client trust account, but I don’t have any client funds in it. Do I have to report it?
Yes. Even if you do not currently hold funds in your client trust account, you must still report and register the account. Further, regardless of whether there are client funds, third-party funds, or no funds in a trust account, an attorney has the Client Trust Account obligations set forth in the standards in rule 1.15.
The definition of a client trust account is “any bank account or accounts opened to receive or hold funds in accordance with rule 1.15(a) of the Rules of Professional Conduct, regardless of the amount of funds in the account, and includes, but is not limited to, any IOLTA account under Business and Professions Code section 6211, subdivision (a) where the interest is paid to the State Bar; and any accounts established under Business and Professions Code section 6211, subdivision (b) where the interest is payable to a client or other person.”
3.2.1 What is the difference between question 1 (IOLTAs) and question 2 (non-IOLTAs) in Step 1?
Question 1 asks whether, to comply with the requirements or prohibitions governing the safekeeping of funds of clients and other persons in rule 1.15 of the California Rules of Professional Conduct, you maintained—or anyone maintained on your behalf—any trust account under Business and Professions Code section 6211, subdivision (a) where the interest is paid to the State Bar, also known as an Interest on Lawyers’ Trust Account (IOLTA), or a similar pooled trust account in another jurisdiction?
Question 2 asks the same question about trust accounts under Business and Professions Code section 6211, subdivision (b) where the interest is payable to a client or other person or similar accounts, also known as non-IOLTA trust accounts, or a similar trust account in another jurisdiction.
When registering a client trust account as part of CTAPP, you must identify the trust account type. The account will either be IOLTA or non-IOLTA; an account will never be both. The account type was established at the time the account was opened and does not change. A California IOLTA must bear the State Bar of California’s Taxpayer Identification Number to ensure that interest or dividends generated by this account will be paid to the State Bar’s IOLTA program. A non-IOLTA will bear the Social Security Number or Tax ID number of the client or third party.
3.3.6 Why am I being asked about failing to reporting within 30 days? Am I in trouble?
Rule 2.2(C) of the Rules of the State Bar requires licensees to report changes in trust account information within 30 days of any change. Many licensees are unaware of this longstanding rule. At this time, there is no penalty for noncompliance with the 30-day update requirement. Answering this question truthfully will not increase the likelihood of a CTAPP compliance review or investigatory audit. Currently, the State Bar is focusing 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.
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