Possible outcomes of the compliance review include:

• Confirmation of compliance with no further action
• Recommendations for best practices for a compliance review with minimal findings
• A mandatory corrective action plan
• Escalation to an investigative audit
• Referral to the Office of Chief Trial Counsel for possible disciplinary action

The compliance review itself is not a disciplinary proceeding. However, serious or unresolved findings may result in a referral to the Office of Chief Trial Counsel. Attorneys who demonstrate good faith effort to comply and correct issues are generally supported with guidance and corrective measures, not discipline.

Some of the most frequent compliance issues include:

• Not performing monthly three-way reconciliations of the trust accounts
• Errors in distribution calculations to both the law firms and clients
• Designated licensee failing to supervise trust account recordkeeping performed by staff, bookkeepers, or outside vendors
• Commingling personal and client funds, often through overpayment or underpayment of withdrawals from the trust account
• Delayed or missing written notice to clients when funds are received on their behalf
• Lack of documentation for deposits and disbursements, or incorrect amounts recorded
• Failure to promptly distribute undisputed funds to the client or third party within 45 days
• Missing or incomplete account journals that do not contain all required fields:

1. Date of each transaction
2. Client related to each transaction
3. Amount of each deposit and disbursement
4. Running balance

• Failure to maintain client ledgers that contain all required fields:

1. Date of each transaction
2. Source of funds (payor) or payee of each transaction
3. Amount of each deposit and disbursement
4. Purpose of each transaction
5. Running balance

You may find client trust accounting resources and training materials on the State Bar’s Client Trust Accounting Resources and Materials webpage, and there is more information about the CTAPP compliance review program on the CTAPP Compliance Review webpage.

The CLS Program certifies law students to provide legal services on a restricted basis under the supervision of a licensed California attorney who is active and in good standing.

You can participate in the program if you are currently enrolled in or have graduated from:

• A Juris Doctor (JD) program: Have successfully completed one full year of studies and have passed or established exemption from the First-Year Law Students’ Examination, and be enrolled and in good academic standing in the second, third, or fourth year of law school.
• A Master of Laws (LLM) program: Have a degree from a law school in a foreign jurisdiction that authorizes the applicant to practice law in that jurisdiction and is acceptable to the State Bar of California under the State Bar’s Guidelines for Applicants with a Foreign Language Degree; have successfully completed one semester or two quarters in an LLM program; be enrolled and in good academic standing in a second or subsequent semester or third or subsequent quarter of an LLM program; and have not failed to take or received results for the first California Bar Examination for which eligible, since first registering with the State Bar of California.
• The Law Office Study (LOS) Program: Have successfully completed one full year in the Law Office Study Program, have passed the First-Year Law Students’ Examination, and be actively continuing the study of law in a law office through the Law Office Study Program.

An applicant who graduates from a JD or LLM program or completes four years of recognized study through the LOS Program is eligible to apply for the CLS Program for up to 30 days after their graduation or completion of studies.