If you need to disassociate a client trust account that is no longer active or held by a firm by which you are no longer employed or in practice with, you should:

1. Log in to your My State Bar Profile.
2. Navigate to the CTAPP reporting section.
3. Locate the account you wish to disassociate in your list of accounts.
4. Click on the plus sign (+) on the right-hand side of the screen to expand options.
5. Select the “Update Connection” tab on the account details pop-up.
6. Change the “Connection to Attorney” to “Disassociated/Added in Error.”
7. You will need to provide a disassociation reason and a disassociation effective date.
8. If you are reporting a disassociation effective date more than 30 days after the disassociation date, the system will prompt you for a reason why you are reporting it after the 30-day update deadline. At this time, there is no penalty for noncompliance with the 30-day update requirement. Answering this question truthfully will not result in an increased likelihood of a CTAPP compliance review or investigatory audit. The State Bar’s current focus is on gathering accurate information, educating licensees about their trust account responsibilities (including the 30-day update requirement), and improving overall compliance. There is a 50-character limit on this field.
9. Click the “Save” button.

This process removes the account from your profile for future reporting periods but maintains the historical record as required.

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.

Rule 2.2(C) of the Rules of the State Bar requires licensees to report changes in trust account information within 30 days of any change. Many licensees are unaware of this longstanding rule. At this time, there is no penalty for noncompliance with the 30-day update requirement. Answering this question truthfully will not increase the likelihood of a CTAPP compliance review or investigatory audit. Currently, the State Bar is focusing on gathering accurate information, educating licensees about their trust account responsibilities (including the 30-day update requirement), and improving overall compliance. There is a 50-character limit on this field.

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

A subordinate lawyer may consult a supervisory lawyer to confirm that duties that are not personally performed are being properly discharged by others in the firm. For example, a subordinate lawyer may ask the attorney who manages the firm’s client trust accounts whether monthly reconciliations are performed on the client trust accounts. 

Absent information to the contrary, the subordinate lawyer may reasonably rely on that guidance in completing the self-assessment.

The required self-assessment is a tool to help attorneys evaluate their current practices and to provide citations to relevant rules and other references, including sections of the Handbook on Client Trust Accounting for California Attorneys. The objective is to promote awareness of duties and facilitate thoughtful consideration of any possible changes to an attorney’s current practices.

Given the great variety of practice settings, including situations where an attorney’s practice is conducted in part or completely in another state with different rules, an attorney might appropriately respond “no” to a self-assessment item. Responding “no” should not be considered a wrong answer when that response accurately reflects an attorney’s current practices. However, if you respond “no” to any question, you may want to consider carefully whether you should make changes to your trust account management practices. Even if you decide not to change your trust account management practices, you should consider documenting in your records the purpose of any “no” responses. The self-assessment questions may be reviewed if you are selected for a compliance review. Documentation will assist the reviewer to quickly understand the purpose of the firm’s practice.

In taking the self-assessment, if an attorney is unsure about how California rules and recordkeeping standards apply to a specific practice setting, an inquiry to the Ethics Hotline research service at 800-238-4427 (toll-free in California) can be helpful. The Ethics Hotline might be able to provide more citations and resource references than the ones included in the self-assessment. The Ethics Hotline cannot provide legal advice, nor tell you how to comply with any of the CTAPP requirements, including the self-assessment.

Only by thoughtfully and honestly completing the self-assessment will an attorney realize the benefits of this compliance tool. Please keep in mind that the self-assessment questions are framed in the present tense and as such, they do not elicit information about prior conduct. Most importantly, what is learned from the self-assessment should inform an attorney’s future conduct in providing competent and professionally responsible services when handling funds and property of clients and others.

Please check to make sure all of your accounts have been registered in Step 2. If all your accounts have been registered, the required account ending balance may be missing in Step 2. You must provide the account ending balance as of December 31 of the reporting period or the date the account was closed.

If all your accounts have been registered and each account has a balance, please review your responses in Step 1. If you chose multiple “Yes” answers requiring trust account registration, for example, in Step 1, in response to question 1 (IOLTAs), you selected “Yes, I will provide or update IOLTA (or similar pooled) account information, including the balance as of December 31, 2025, via My State Bar Profile …” and, in response to question 2 (non-IOLTAs), you also selected “Yes, I will provide or update non-IOLTA account information, including the balance as of December 31, 2025, via My State Bar Profile …,” based on your selected responses you are required to register both an IOLTA and a non-IOLTA trust account via My State Bar Profile. If you only have one trust account, please revise your response to either question 1 or question 2. A trust account can never be both an IOLTA and a non-IOLTA.

Similarly, if you selected multiple “Yes” responses requiring trust account registration to question 1 (e.g., “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 IOLTA account information, including the balance as of December 31, 2025, via Agency Billing …”), based on your selected responses, you are required to register multiple IOLTAs via My State Bar Profile and Agency Billing. If you only have one IOLTA, please revise your responses to question 1 in Step 1.

Unless exempt (see FAQ 2.3, above), California licensees, regardless of where they practice, must still comply with the CTAPP reporting requirements. To answer Step 1 (Annual Client Trust Account Reporting) questions, licensees must determine whether they are responsible for client funds and funds entrusted by others under the provisions of rule 1.15 of the California Rules of Professional Conduct. (See Rules Prof. Conduct, rule 8.5.) If so, because rule 1.15 of the California Rules of Professional Conduct requires attorneys who handle trust funds to hold those funds in one or more client trust accounts labeled as a “Trust Account,” or words of similar import, the licensee must answer “yes” to at least one of the CTAPP Annual Client Trust Account Reporting questions of whether they maintained any trust accounts 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 trust accounts under Business and Professions Code section 6211, subdivision (b) where the interest is payable to a client or other person, also known as non-IOLTA trust accounts, and complete the remaining CTAPP requirements.

Only if the licensee is not responsible for any client funds and funds entrusted by others under rule 1.15 of the California Rules of Professional Conduct may the licensee answer “no” to the CTAPP Annual Client Trust Account Reporting questions. 

For information on reporting an IOLTA account outside California, please refer to CTAPP FAQ 4.3, below.

Unless exempt (see FAQ 2.3, above), California licensees, regardless of where they practice, must still comply with the CTAPP reporting requirements. A licensee who was responsible for client funds and funds entrusted by others under the provisions of rule 1.15 of the California Rules of Professional Conduct must, annually, register each and every trust account in which the licensee held such funds at any time during the reportable time period by identifying account numbers and financial institutions in a manner prescribed by the State Bar for such reporting. There is no exception for out-of-state accounts.

In general, under rule 1.15(a) of the Rules of Professional Conduct, a licensee’s trust accounts must be maintained in California, or, with the written consent of the client, in another jurisdiction where there is a substantial relationship between the client or the client’s business and that other jurisdiction. Therefore, if licensees are entitled to hold IOLTA accounts outside of California, they will need to register those accounts as non-CA IOLTA accounts by selecting “Add Account” in My State Bar Profile, or, if using the Agency Billing application, selecting “Manage Accounts.”