4.4 I have an IOLTA account outside California. In question 2 of the Step 3 (Self-Assessment), how can I affirm that any funds held in a California IOLTA account are maintained in an IOLTA-eligible institution identified on the State Bar of California’s website if the account is held outside California by an institution that is not on the approved list?
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.
4.5 Do I need to report non-U.S. bank accounts?
Unless exempt (see FAQ 2.3, above), California licensees, regardless of where they practice, must still comply with the CTAPP reporting requirements. Licensees must report and register each and every trust account in any location if (1) they acted as a signatory or exercised managerial or primary administrative oversight for a trust account held pursuant to rule 1.15 of the California Rules of Professional Conduct, or (2) were otherwise responsible for complying with any of the requirements or prohibitions in rule 1.15 of the California 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 (e.g., responsibilities for safekeeping of funds, to identify and discharge liens, notify clients that funds have been received, etc.).
Currently, CTAPP reporting features do not allow licensees or firm administrators to enter non-U.S. routing and account numbers. Therefore, for all non-U.S. trust accounts, in Step 1 (Annual Client Trust Account Reporting), please check the box next to “Yes, I will provide or update IOLTA and/or non-IOLTA account information, including the balance as of December 31, 2025, via My State Bar Profile” for the appropriate question, depending on the type of account. Then, during Step 2 (Account Registration), check the checkbox next to “Other” under the sentence, “If you selected Yes to the IOLTA or Non-IOLTA question in Step 1, but are unable to register that IOLTA (CA or Non-CA) and/or Non-IOLTA because you do not have some of the required information, please describe why below,” and, in the box provided, list all non-U.S. bank accounts, including bank name, account number, and country of origin. In future years, we expect enhancements to the reporting application will make it possible for licensees and agencies to report non-U.S. trust account information.
5.1 Can my firm complete my CTAPP reporting on my behalf?
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.
Does participation in an activity as a moderator qualify for MCLE credit?
No, MCLE credit is only available to speakers, panelists, and regular attorney participants.
What is the State Bar DEI Leadership Seal program?
The DEI Leadership Seal Program is an optional program that employers with California attorneys can participate in to signal their commitment to diversity, equity, and inclusion (DEI).
As part of its 2022 Diversity Report Card, the State Bar of California published Calls to Action that legal employers and attorneys can implement to support greater DEI in the workplace. The DEI Leadership Seal program recognizes California legal employers that commit to and implement specific DEI action items.
How do I apply for participation in the DEI Leadership Seal program?
What does my organization have to do to participate?
An employer may participate in the program as either a committed participating employer or a seal recipient. To be recognized as a committed participating employer, an employer must commit to implementing at least five of the ten Action Items. Committed participating employers will have one year to implement the selected Action Items. The one-year implementation window starts when an employer’s application is approved. Once an employer implements at least five of the ten Action Items, it may be deemed a seal recipient.
Committed participating employers will be listed on the State Bar website. DEI Leadership Seal recipients will also be listed on the State Bar website and receive a seal that they can use on their web and print materials to signal their participation in the program to employees, job candidates, clients, and more.
What if my employer has already implemented at least five of the ten Action Items? Do I need to wait a year to receive the DEI Leadership Seal?
If your organization has already implemented five of the ten Action Items (including the two that are required) at the time of application, please indicate that on your application and provide the requested documentation. If your employer’s implementation of the Action Items is sufficient, you can receive the DEI Leadership Seal as soon as your application is reviewed.
Are there different implementation or recognition levels in the DEI Leadership Seal program?
The DEI Leadership Seal program recognizes bronze, silver, and gold seal recipients, based on the number of Action Items implemented.
• Employers that implement five Action Items are eligible to be recognized as bronze-tier recipients.
• Employers that implement seven Action Items are eligible to be recognized as silver-tier recipients.
• Employers that implement nine Action Items are eligible to be recognized as gold-tier recipients.
All participating employers, regardless of tier, must commit to implementing the first two Action Items and then select from the remaining eight.
My employer is a committed participating employer. By when must the Action Items be implemented?
Committed employers should use the Tier Advancement form to identify and document which Action Items have been implemented. Tier Advancement forms are accepted on a rolling basis. Tier Advancement form due dates will be posted on our website.
