Guidance on resolving frequent problems in annual CTAPP reporting.
Answering Questions About IOLTA and Non-IOLTA Accounts
Disassociate a Client Trust Account
Editing Previously Registered Accounts
Addressing Delayed Account Updates Under Rule 2.2 of the Rules of the State Bar
Self-Assessment Questions: Answer Truthfully
Answering Questions About IOLTA and Non-IOLTA Accounts
(Helpful if you get an error message)
Many licensees have questions about how to respond to the questions regarding IOLTA and non-IOLTA accounts:
- If you answer “Yes” to the Screening Question, you must answer both Step 1 (Annual Client Trust Account Reporting) and Step 2 (Account Registration).
- An IOLTA account is an Interest on Lawyers Trust Account where you hold client funds that are nominal in amount or held for a short period and the interest is paid to the State Bar. See CTAPP FAQ 1.3 for more information.
- A non-IOLTA account is any other client trust account you maintain that doesn't qualify as an IOLTA account (typically used for larger amounts or longer-term holdings) and the interest is payable to a client or other person. See CTAPP FAQ 1.3 for more information.
- If you don't maintain either type of account and such account is not maintained on your behalf, you should go back and answer “No” to the initial Screening Question.
- Don’t not select “Yes…” to both question 1 (IOLTAs) and question 2 (non-IOLTAs) in Step 1 for the same account – you will be unable to complete your CTAPP reporting. A trust account will either be IOLTA or non-IOLTA; an account will never be both. If you do not know which trust account type you hold, contact your financial institution to confirm. The account type was established at the time the account was opened and does not change.
- If you answer “Yes” to either an IOLTA or non-IOLTA question, you'll need to provide the required account information for each account you maintain or your firm or organization will need to provide it on your behalf, unless you are no longer employed by or in practice with that firm or organization. Please see CTAPP FAQ 3.2.2 for a table of account types and the applications the accounts must be registered through for each response in Step 1.
Disassociate a Client Trust Account
If you need to disassociate a client trust account that is no longer active or not associated with you:
- Log in to your My State Bar Profile.
- Navigate to the CTAPP reporting section.
- Locate the account you wish to disassociate in your list of accounts.
- Click on the plus sign (+) on the right-hand side of the screen to expand options.
- Select "Update Account Information"
- In the prompt window, go to the “Update Connection” tab.
- Change the status to “Disassociate,” select the reason from the drop-down menu, and enter the effective date of disassociation.
- If you are reporting more than 30 days after the disassociation, provide an explanation for the late update in the box that appears after you enter the date.
This process removes the account from your profile for future reporting periods but maintains the historical record as required. Note: Do not add a “close date” to an open trust account to disassociate from it. A close date must only be added when the trust account is closed at the financial institution.
Complete CTAPP Reporting Requirement
How to Report Client Trust Account Updates
Editing Previously Registered Accounts
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 now be required to provide the open date for your registered accounts.
Complete CTAPP Reporting Requirement
Addressing Delayed Account Updates Under Rule 2.2 of the Rules of the State Bar
Some licensees are concerned about how to answer the question regarding why they didn't update their account information within the 30-day period required by rule 2.2 of the Rules of the State Bar.
- Important clarification: 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 and improving overall compliance.
- If you failed to update your account information within 30 days of a change, simply select the most appropriate reason from the dropdown menu and proceed with your reporting.
How to Report Client Trust Account Updates
Rules of the State Bar, Title 2, Division 1, rule 2.2
Addressing Delayed Account Updates Under Rule 2.2 of the Rules of the State Bar
Some licensees are concerned about how to answer the question regarding why they didn't update their account information within the 30-day period as required by rule 2.2 of the Rules of the State Bar.
- Important clarification: 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 education about the 30-day update requirement, gathering accurate information, and improving overall compliance.
- If you failed to update your account information within 30 days of a change, simply select the most appropriate reason from the drop-down menu and proceed with your reporting.
How to Report Client Trust Account Updates
Rules of the State Bar, Title 2, Division 1, rule 2.2
Self-Assessment Questions: Answer Truthfully
Many licensees have questions about how to complete the self-assessment portion of the CTAPP reporting:
- Responding “No” to self-assessment items is appropriate when it accurately reflects your current practices, especially given the variety of practice settings.
- A “No” response is not considered incorrect when it truthfully represents your situation (e.g., when practicing partly or completely in another state with different rules or when you no longer maintain funds under rule 1.15).
Have a question? Contact us.