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.

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.

A licensee who fails to satisfy the requirements of CTAPP and its associated rules by the deadline will be assessed a noncompliance penalty. If the licensee still does not comply, they will be enrolled as an inactive licensee of the State Bar under the rules adopted by the Board of Trustees of the State Bar. Inactive enrollment imposed for noncompliance with the requirements of this program is cumulative and does not preclude a disciplinary proceeding or other actions for violations of the State Bar Act, the Rules of Professional Conduct, or other applicable laws. (See FAQ 2.12, below, for a discussion of the unauthorized practice of law by inactive licensees.)

Your reporting is complete if: 

• You answered “no” to the CTAPP Screening Question and submitted your Final Declaration; or
• You answered “yes” to the CTAPP Screening Question and:
  • Completed Step 1 (Annual Client Trust Account Reporting);
  • Registered your trust accounts in Step 2 (Account Registration) or confirmed your firm registered your trust accounts on your behalf through Agency Billing and you or your firm updated the year-end account balance for all registered trust accounts;
  • Completed Step 3 (Self-Assessment);
  • Completed Step 4 (Annual Certification of Compliance); and
  • Submitted your Final Declaration.

You can verify your compliance status by logging in to My State Bar Profile and reviewing your Compliance Dashboard. Each box on the dashboard displays reminders related to each of your annual requirements, including your current CTAPP status. Click the blue button on the relevant tile to complete outstanding tasks. 

If your individual reporting is complete, you can review your responses and determine if your firm has registered accounts on your behalf using the “View a Summary of your CTAPP Annual Reporting” link on the CTAPP Annual Reporting tile on the Compliance Dashboard page. You will not invalidate your declaration by reviewing this summary.

If you have already completed your CTAPP reporting for the current period and you want to change an answer before the reporting deadline, you can access the CTAPP reporting page by logging in to My State Bar Profile. On your Client Trust Reporting page (third blue tab at the top), click the CTAPP Annual Reporting tile. You can click through the pop-up warning that says you have already submitted your CTAPP Annual Reporting declaration and that you will have to resubmit your declaration, or you will be out of compliance. NOTE: Even if you make no changes, be sure to click all the way through and resubmit your declaration.

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.

If you do not maintain a trust account, a trust account is not maintained on your behalf, and you do not need a trust account because you are not 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 can answer “no” to the Screening Question: “At any point during the reporting period of January 1, 2025–December 31, 2025, or, if you are a new licensee who must pay your initial license fees pursuant to rule 2.12 of the Rules of the State Bar, from your date of admission through the following December 31, 2025, or the due date for payment of fees, whichever is earlier, were you 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?” After submitting that response and declaring the information is true, your compliance with CTAPP will be deemed complete.

If your practice does not require a client trust account, you do not need to open one to report it to the State Bar as part of the CTAPP requirements. If you have questions about using trust accounts, including whether you are responsible for complying with any of the requirements or prohibitions in rule 1.15 or whether you need a trust account, please contact the State Bar’s Ethics Hotline research service at 800-238-4427 (toll-free in California). The Ethics Hotline might be able to provide helpful citations and resource references. The Ethics Hotline cannot provide legal advice, nor tell you how to comply with any of the CTAPP requirements, including the self-assessment.

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.”

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.

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.