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.

If you answer “Yes” to the Screening Question indicating that you are responsible for complying with any of the requirements or prohibitions governing the safekeeping of funds of clients and other persons under rule 1.15 of the California Rules of Professional Conduct, you must maintain a trust account—or have one maintained on your behalf—to receive and hold the entrusted funds. Therefore, you must answer “Yes …” to at least one Step 1 question. The answer you choose depends on who will be registering the account with the State Bar.

For example, if you select “Yes, I will provide or update IOLTA/non-IOLTA account information, including the balance as of December 31, 2025, via My State Bar Profile …” in response to either question 1 and/or question 2, you must complete all CTAPP reporting requirements and register a corresponding IOLTA, non-IOLTA, or both, depending on the question(s) to which you select this answer, in Step 2 (Account Registration) in My State Bar Profile.

If you select “Yes, a firm or organization I am currently employed by or in practice with will provide or update the account information via Agency Billing, including the balance as of December 31, 2025” in response to either question 1 and/or question 2, you must complete all CTAPP reporting requirements. A firm or organization can only register a corresponding IOLTA, non-IOLTA, or both, depending on the question(s) to which you select this answer, via the State Bar’s Agency Billing platform. Regardless of whether you select this answer, it remains your responsibility to ensure that all necessary account details are registered, including the December 31 balance. You should be sure to confirm with your firm or organization administrator that they will register the required information via the State Bar’s Agency Billing platform by the deadline.

If you select “Yes, however, I am no longer employed by or in practice with the firm or organization. I understand that I am not required to register trust accounts that are maintained by a firm or organization that I am no longer employed by or in practice with as of December 31, 2025” and you did NOT also select any of the other “Yes …” answers, you do not have to register any accounts in Step 2 (Account Registration). You are not required to register accounts that are maintained by a firm or organization that you are no longer in practice with as of December 31, 2025. If there are no other accounts that you maintained or were maintained on your behalf, you may proceed to Step 3 (Self-Assessment).

You may choose as many “Yes” answers to the same question as are applicable to your situation. You may not simultaneously select a “Yes” and “No” answer to the same question. If you choose multiple “Yes” answers requiring trust account registration, you must have multiple trust accounts registered in Step 2. For example, if you choose “Yes, I will provide or update IOLTA account information, including the balance as of December 31, 2025, via My State Bar Profile …” and “Yes, a firm or organization I am currently employed by or in practice with will provide or update the IOLTA account information, including the balance as of December 31, 2025, via Agency Billing …” in response to question 1, you must have two IOLTA accounts registered in Step 2, one registered via My State Bar Profile and one registered via Agency Billing.

Your responses to questions 1 (IOLTA) and 2 (non-IOLTA) in Step 1 should never be “No …” and “No …” because you answered “Yes” to the Screening Question indicating that you were responsible for complying with any of the requirements or prohibitions governing the safekeeping of funds of clients and other persons under rule 1.15 of the California Rules of Professional Conduct.

Please see the tables, below, to see the Account Type and the Application Type (the application through which the account must be registered) (see Image 1) for each response to the Step 1 questions.

Image 1. My State Bar Profile Step 2 Account Registration Grid

Image

As a sole practitioner, you likely maintain the account yourself or have a bookkeeper maintain the account and have access to the account information (e.g., routing number, account number, balance, etc.). If so, you can provide or update the account information via My State Bar Profile. 

The “firm or organization I am currently employed by or in practice with will provide or update the account information via Agency Billing” option is for lawyers who do not have access to the account information and who have a firm administrator who uses the State Bar’s Agency Billing platform, and the administrator will register the firm trust accounts on behalf of the firm lawyers. If this applies to you, you may select that answer in Step 1 and, in Step 2 (Account Registration), if the firm administrator has not already registered the account details, you will select the checkbox next to “My firm or organization administrator informed me that the IOLTA and/or Non-IOLTA account details will be reported by my firm or organization on my behalf through the State Bar's Agency Billing application. I understand that it is my responsibility to ensure that my CTAPP reporting is complete, including that my firm or organization reports any account details maintained on my behalf.” It is your responsibility to ensure that all necessary account details are registered, including the December 31 balance. You should be sure to confirm with your firm administrator that they will register the required information via the State Bar’s Agency Billing platform by the deadline.

For help registering your trust accounts in Step 2 of CTAPP in My State Bar Profile, please see the Client Trust Account Updates Guide.

The State Bar is in the process of updating all bank names according to the names listed in the official Registrar of Routing Numbers for the American Bankers Association. Therefore, if your bank name changed, but your routing number and account number stayed the same, the State Bar will update the bank name to your existing trust account record. You do not need to do anything to change the bank name. You will still need to provide the year-end balance for your existing trust account.

The trust account reporting system does not allow changes to routing numbers or account numbers of previously registered trust accounts. To report this change, please close the registration of the existing account by clicking the “Update Account Information” link and then entering, in the “Edit Close Date” tab, the date the account was changed to the new routing and account number. You will also need to enter the balance on that date. 

You can then register the account with the new routing number and account number. In the open date field, please enter the date the account was changed to the new routing and account number. Please be sure to enter the bank balance of the new account as of December 31.

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.

Please check column 2 (Application Type) of the Step 2 account grid. If the account was registered through Agency Billing you can only update the Account Connection to “Disassociated/Added in Error.” To do so, please see FAQ 3.3.4. For all other changes, including adding a balance, firm name changes, etc., please contact your firm administrator. 

If your account was previously registered as a “Ind. CTA or Non-CA IOLTA” account type, you will be required to update your account type to “IOLTA,” “non-CA IOLTA,” or “non-IOLTA.” 

If you were not previously required to provide an open date, you will be required to provide the open date for each of your registered accounts. 

If the account was registered through My State Bar Profile, you can edit some details of an existing account. To do so, you should:

1. Locate the account you wish to disassociate in your list of accounts.
2. Click on the plus sign (+) on the right-hand side of the screen to expand options.
3. Select the “Edit Balance,” “Update Connection,” “Update Account Type,” “Edit Close Date,” “Edit Open Date,” or “Edit Firm Name” tab depending on what information you want to update.
4. Update the information.
5. Click the “Save” button.

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.

The CTAPP self-assessment questions can be viewed in the CTAPP self-assessment preview.