Yes. Employers may choose to commit to and implement the Action Items for either their entire organization or only their legal department or team. If an employer commits to and implements the Action Items only for their legal department, only that department would be listed as a participating employer and eligible to use the DEI Leadership Seal on its materials.

Committed participating employers who have implemented five or more Action Items and want to receive the DEI Leadership Seal before the June deadline must complete and submit a DEI Leadership Seal Tier Advancement Application and supporting documentation. There will be several opportunities throughout the year for committed employers to submit this documentation and receive the seal early. To be considered for tier advancement, please submit your application and supporting documentation.

Please check to make sure all of your accounts have been registered in Step 2. If all your accounts have been registered, the required account ending balance may be missing in Step 2. You must provide the account ending balance as of December 31 of the reporting period or the date the account was closed.

If all your accounts have been registered and each account has a balance, please review your responses in Step 1. If you chose multiple “Yes” answers requiring trust account registration, for example, in Step 1, in response to question 1 (IOLTAs), you selected “Yes, I will provide or update IOLTA (or similar pooled) account information, including the balance as of December 31, 2025, via My State Bar Profile …” and, in response to question 2 (non-IOLTAs), you also selected “Yes, I will provide or update non-IOLTA account information, including the balance as of December 31, 2025, via My State Bar Profile …,” based on your selected responses you are required to register both an IOLTA and a non-IOLTA trust account via My State Bar Profile. If you only have one trust account, please revise your response to either question 1 or question 2. A trust account can never be both an IOLTA and a non-IOLTA.

Similarly, if you selected multiple “Yes” responses requiring trust account registration to question 1 (e.g., “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 IOLTA account information, including the balance as of December 31, 2025, via Agency Billing …”), based on your selected responses, you are required to register multiple IOLTAs via My State Bar Profile and Agency Billing. If you only have one IOLTA, please revise your responses to question 1 in Step 1.

The only licensees who are exempt from the annual reporting requirement are licensees who were on voluntary inactive status for the entirety of the reportable time period. All other licensees, including those who were active, suspended, or not entitled to practice law at any point in the reportable time period, are required to complete the CTAPP reporting requirements for that reportable time period.

When a licensee performs both legal and non-legal professional services for a client, the licensee is subject to the Rules of Professional Conduct with respect to all of those services. (See Cal. State Bar Formal Opn. Nos. 1982-69, 1995-141, and 1999-154.) 

Therefore, a key question is whether the licensee is performing legal services and, as a result, is subject to rule 1.15 and the other Rules of Professional Conduct. If not, and the licensee is merely a real estate broker who happens to be a lawyer, rule 1.15 may not apply. Similarly, if the licensee is a trustee but did not perform any legal services related to the creation of the trust and does not perform any legal services related to the trust, rule 1.15 may not apply. On the other hand, if the licensee is acting as both the real estate lawyer and broker, and the lawyer receives entrusted funds from, or for, the transaction, rule 1.15 would apply, and any accounts need to be reported and registered as part of the licensee’s CTAPP compliance. The same is true of lawyers providing other non-legal professional services, regardless of whether they, as a trustee, for example, report to the probate court.

If you have further questions on dual capacity, including whether you are responsible for complying with any of the requirements or prohibitions in rule 1.15, 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.

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.

A subordinate lawyer may consult a supervisory lawyer to confirm that duties that are not personally performed are being properly discharged by others in the firm. For example, a subordinate lawyer may ask the attorney who manages the firm’s client trust accounts whether monthly reconciliations are performed on the client trust accounts. 

Absent information to the contrary, the subordinate lawyer may reasonably rely on that guidance in completing the self-assessment.

The State Bar collects information on attorneys’ pro bono and reduced fee hours to better understand how these services are being provided across the profession. The data will be analyzed to identify trends, support efforts to expand access to legal services, and help address the justice gap. All reported data will be aggregated and not linked to individual attorneys.

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.

Make sure that you have completed all interactive elements on the screen. The “NEXT” button will only activate once all of the screen elements have been completed. In addition, please allow the screen seek bar to progress on its own. If you manually drag it to complete the course, the “NEXT” button may not activate properly.