Yes. Employers may choose to commit to and implement the Action Items for either their entire firm or only their California offices. If an employer commits to and implements the Action Items for specific offices, only those offices would be listed as participating employers and eligible to use the DEI Leadership Seal on their materials.

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.

Please email DEILeadershipSeal@calbar.ca.gov with any questions or feedback.

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.

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.

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

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

Law firms and organizations can complete only one step of the requirements for the lawyers who work for them, which is registering trust accounts on their behalf. Even if the firm registers the account on behalf of the lawyer, the lawyers must still log in to My State Bar Profile and complete the initial report of whether they maintained a client trust account or one was maintained on their behalf, the self-assessment, the certification that they are knowledgeable about and in compliance with the rules regarding the safekeeping of funds, and the declaration.

If the firm or organization that you are currently employed by or in practice with is registered with the State Bar’s Agency Billing platform, the firm or organization may register the client trust accounts on the lawyer’s behalf. However, the State Bar must receive the trust account registration data by the reporting deadline. If you or your firm or organization fail to report this information by the deadline, you will be assessed a noncompliance penalty.

Please contact your firm or organization administrator to confirm whether they will report the trust account registration data on your behalf. The firm must identify, via the Agency Billing platform, each licensee who is covered by the firm’s submission of account information on behalf of the firm’s lawyers.

Lawyers can determine whether their firm has reported account information on their behalf during the CTAPP registration process in My State Bar Profile or, if they have already completed their individual reporting requirements, by clicking on the “View a Summary of your CTAPP Annual Reporting” link on the CTAPP Annual Reporting tile on the Compliance Dashboard page.

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.

This resource walks you through reporting pro bono hours on My State Bar Profile.

Click the ← MY STATE BAR PROFILE button at the top right of the e-learning portal to log out and return to the My State Bar Profile page.