The State Bar has created a Resource Guide that provides tips and best practices to consider when implementing the Action Items. The guide is intended to be one tool to help organizations develop and achieve their DEI goals and is not intended to provide step-by-step instructions.

The State Bar’s mission is to protect the public and includes the primary functions of licensing, regulation and discipline of attorneys; the advancement of the ethical and competent practice of law; and support of efforts for greater access to, and inclusion in, the legal system. Additionally, the State Bar of California’s strategic goals include “promot[ing] diversity and inclusion in the legal system.”

The State Bar takes reasonable precautions and has security measures in place to protect the personal information we collect and maintain against loss, unauthorized access, use, modification, or disclosure. We take the following measures to secure the information that is stored within our applications: 

• Protecting the security of individuals’ personal information during transmission by using encryption protocols and software.
• Storing personal information in secure locations in an encrypted format.
• Ensuring staff is trained on procedures for the management and release of personal information. This information can only be accessed by staff whose work requires it.
• Conducting periodic audits to ensure that proper information management policies and procedures are being followed.

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.

A lawyer who has no responsibility to comply with any of the requirements or prohibitions in rule 1.15 and a lawyer who is responsible for complying only with 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, can comply with their reporting requirements by answering “no” to the screening question as to whether they 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 and thereafter submitting their declaration. Lawyers who have no such responsibilities include:

• A government lawyer-employee who is not responsible for the safe keeping of entrusted funds;
• An in-house counsel who is employed by their client and does not receive or hold client funds or funds entrusted by others;
• Law professors who do not represent clients that involve any entrusted funds and do not otherwise receive or hold entrusted funds;
• A lawyer in a large firm who only performs document review, has no interaction with any clients, and has no responsibilities to carry out any of the duties under rule 1.15;
• A lawyer who bills for fees and costs after completion of the work and therefore does not take advance fees and their practice does not involve the receipt of any other funds in which a client or third party has an interest (e.g., client settlement funds, etc.); and
• A lawyer who does not receive or hold any entrusted funds except for flat fees paid in advance and properly deposited into a lawyer’s or law firm’s operating account in accordance with the disclosure and agreement requirements in rule 1.15(b) of the Rules of Professional Conduct.

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.

Under Business and Professions Code section 6212, attorneys that established an IOLTA account pursuant to subdivision (a) of Business and Professions Code section 6211, may hold IOLTA accounts only at eligible financial institutions. Rule 1.15(a) of the California Rules of Professional Conduct generally requires that trust accounts for California clients be maintained in California. You are permitted to hold client funds in an IOLTA account outside California if your client is from somewhere other than California or if your California client has a substantial relationship with the other jurisdiction and has provided written consent. If your practice meets those criteria and you do not have a California IOLTA, you may select “I do not have a California IOLTA” as your response.

For purposes of this reporting requirement, board service for a legal aid nonprofit would qualify because all board work with such an organization is enabling the delivery of legal services to the indigent (since these organizations primarily serve indigent California residents). Please note that some legal aid providers and other nonprofits for which attorneys provide pro bono legal services may also ask attorneys to report pro bono hours, but the definition for pro bono legal services may vary for their purposes. Attorneys should confirm definitions with the entity before reporting pro bono hours to the entity.  

Your device may be referring to an earlier memory cache (version) of the course and may not be refreshing correctly. Try carrying out each of these options until you resolve the issue: 

1. Clear your browser’s memory cache/history.
2. Try using a different Internet browser. The following are optimal:
   Windows 7/10: Google Chrome, Internet Explorer 11 or above
   iOS: Safari
3. Try launching the course on a different device.

The plan allows attorneys to spread their total fee into smaller, manageable payments while ensuring compliance with their financial obligations.