While a licensee is on inactive status, that licensee cannot practice law. An inactive licensee who engages in the practice of law may be guilty of a misdemeanor. (See Bus. & Prof. Code, §§ 6125–6126, 6068, subd.(a), & 6106. See also In the Matter of Burke (Review Dept. 2016) 5 Cal. State Bar Ct. Rptr. 448.) Additionally, a licensee on inactive status may have a duty to inform their client(s) or a tribunal that they are ineligible to practice law. (See Rules of Professional Conduct 1.4 and 3.3.) If you have further questions about the unauthorized practice of law, 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.

Reinstatement of your license requires payment of any applicable fees, completion of the past due CTAPP reporting requirements, and applying for reinstatement. To submit payment of applicable fees, please log in to My State Bar Profile and click the “Pay Fee” link on the CTAPP Annual Reporting tile on your Compliance Dashboard or click the blue “Make a payment” button on the Profile Summary page to go to the “Annual Fee” page. You should go to the Annual Fee page to pay outstanding fees even if you have already paid your annual licensing fee for 2026. From there, click the blue “Calculate and pay my fees” button to see a breakdown of the fees owed. Click continue and follow the steps to complete your payment.

If you were involuntarily enrolled as inactive for noncompliance in 2026, you can complete your CTAPP reporting in My State Bar Profile and then complete and submit the first page of the CTAPP Noncompliance Reinstatement Form. If you were involuntarily enrolled as inactive for CTAPP noncompliance in 2023, 2024, or 2025, you will need to complete and submit the first page of the CTAPP Noncompliance Reinstatement Form and the attached CTAPP reporting forms for all missing years.

A lawyer must report any changes to their client trust account to the State Bar within 30 days. A lawyer may add or close an account using the 30-day reporting window in My State Bar Profile, and a firm administrator may add or close an account or add or remove an attorney from an account through the 30-day reporting window in the Agency Billing platform. When a firm administrator adds a new attorney or removes an attorney from a trust account, they provide the effective date and reason for the disassociation as part of the reporting.

A licensee is “responsible for client funds and funds entrusted by others under the provisions of rule 1.15 of the Rules of Professional Conduct” within the meaning of this rule if, at any point during the reporting period, they acted as a signatory on a trust account—even if there was no money in the account, exercised managerial or primary administrative oversight for a trust account, or were 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 requirements and prohibitions in rule 1.15 are not limited to banking and recordkeeping duties and 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 the duty to identify and discharge liens.

Lawyers who were responsible for entrusted funds in the reporting period must also register, or have their firm register through the State Bar’s Agency Billing application, all client trust accounts, take a self-assessment of client trust account management practices, and certify their compliance with requirements of rule 1.15 of the Rules of Professional Conduct.

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.

Question 1 asks whether, to comply with the requirements or prohibitions governing the safekeeping of funds of clients and other persons in rule 1.15 of the California Rules of Professional Conduct, you maintained—or anyone maintained on your behalf—any trust account under Business and Professions Code section 6211, subdivision (a) where the interest is paid to the State Bar, also known as an Interest on Lawyers’ Trust Account (IOLTA), or a similar pooled trust account in another jurisdiction? 

Question 2 asks the same question about trust accounts under Business and Professions Code section 6211, subdivision (b) where the interest is payable to a client or other person or similar accounts, also known as non-IOLTA trust accounts, or a similar trust account in another jurisdiction. 

When registering a client trust account as part of CTAPP, you must identify the trust account type. The account will either be IOLTA or non-IOLTA; an account will never be both. The account type was established at the time the account was opened and does not change. A California IOLTA must bear the State Bar of California’s Taxpayer Identification Number to ensure that interest or dividends generated by this account will be paid to the State Bar’s IOLTA program. A non-IOLTA will bear the Social Security Number or Tax ID number of the client or third party.

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

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.

For help registering your trust accounts in Step 2 of CTAPP in My State Bar Profile, please see the Client Trust Account Updates Guide.

The State Bar is in the process of updating all bank names according to the names listed in the official Registrar of Routing Numbers for the American Bankers Association. Therefore, if your bank name changed, but your routing number and account number stayed the same, the State Bar will update the bank name to your existing trust account record. You do not need to do anything to change the bank name. You will still need to provide the year-end balance for your existing trust account.

The trust account reporting system does not allow changes to routing numbers or account numbers of previously registered trust accounts. To report this change, please close the registration of the existing account by clicking the “Update Account Information” link and then entering, in the “Edit Close Date” tab, the date the account was changed to the new routing and account number. You will also need to enter the balance on that date. 

You can then register the account with the new routing number and account number. In the open date field, please enter the date the account was changed to the new routing and account number. Please be sure to enter the bank balance of the new account as of December 31.