Complete CTAPP reporting requirement

Learn how to complete your annual CTAPP reporting requirement.

Your annual Client Trust Account Protection Program (CTAPP) should be completed online through your My State Bar Profile

To comply with the CTAPP reporting requirements, log into your My State Bar Profile and click the "Client Trust Reporting" link in your profile menu.

On the "Client Trust Accounts Reporting Requirements" landing page, click the "CTAPP Annual Reporting" option to complete your CTAPP reporting requirements. 

Note: Your current CTAPP compliance status is indicated on your Compliance Dashboard. 

The CTAPP annual reporting includes the following steps: 

  1. Answer the screening question
  2. Answer the reporting questions
  3. Register your account(s)
  4. Complete the self-assessment
  5. Submit the annual certification
  6. Submit the final declaration to complete the reporting process

Continue reading below for a step-by-step guide on how to fulfill your CTAPP annual reporting requirement.

Screening Question

The initial screening question asks whether, at any time during the reporting period, you were responsible for complying with the requirements or prohibitions related to the safekeeping of funds belonging to clients or others, as outlined in rule 1.15 of the California Rules of Professional Conduct.
  • If you answer yes, you must complete the remaining steps of the CTAPP annual reporting process.
  • If you answer no,  you may proceed directly to submitting the Final Declaration, unless you have registered accounts. If any accounts are registered, you will be directed to Step 2 and you must disassociate or close the accounts before submitting the Final Declaration

Step 1: Respond to reporting questions

Step 1 requires you to respond to two reporting questions about whether you maintained, or your firm maintained on your behalf, IOLTAs and/or non-IOLTAs during the reporting period. Select applicable options and click "Save & Continue" to proceed. 

 

Step 2: Account Registration 

Step 2, if applicable, requires that you register accounts maintained during the reporting period.

Note: Based on your Step 1 responses, you must register the indicated accounts through the specified application. Your CTAPP reporting will not be considered complete until you fulfill the account registration requirements according to your Step 1 responses. 

  1. IOLTA Accounts

    • If you maintained the IOLTA account and you selected that you would provide required account information via My State Bar Profile, a CA-IOLTA or Non-CA IOLTA account must be registered through My State Bar Profile with the December 31 ending balance reported. Your firm cannot report this information on your behalf via Agency Billing.
    • If your current firm/organization maintained the IOLTA account and you selected that your current firm would provide the required account information via Agency Billing, the CA-IOLTA or Non-CA IOLTA account must be registered through Agency Billing with the December 31 ending balance reported. You cannot report this information through My State Bar Profile.
  2. Non-IOLTA Accounts

    • If you maintained the Non-IOLTA account and you selected that you would provide required account information via My State Bar Profile, the Non-IOLTA account must be registered through My State Bar Profile with the December 31 ending balance reported. Your firm cannot report this information on your behalf via Agency Billing.
    • If your current firm/organization maintained the Non-IOLTA account and you selected that your current firm would provide the required account information via Agency Billing, the Non-IOLTA account must be registered through Agency Billing with the December 31 ending balance reported. You cannot report this information through My State Bar Profile.

Important: It is your responsibility to ensure that all required accounts are registered. CTAPP reporting will remain incomplete until all necessary account information is accurately submitted.

If needed, you may go back to Step 1 to update your response.

    1. View how to add a new account
    2. View how to report the required balance for previously registered accounts. 

    Adding accounts

    On Step 2, click "Add Account" to register a new account.

    To add a new IOLTA, non-CA IOLTA, and/or non-IOLTA account, you must:

    1. Select the account type (IOLTA, non-CA IOLTA, or non-IOLTA).
    2. Enter the firm name or organization associated with the account.
    3. Enter the account routing number. 
    4. Enter the account number.
    5. Enter the account ending balance as of December 31, 2024. Note, you are not required to provide the account ending balance when adding an account, however, you will be required to provide the ending balance as of December 31, 2024 prior to submitting your final declaration.
    6. Enter the date the account was opened.
    7. Enter the state account is held.

    Note:

    • You must select the account type before entering any other account information.
    • When entering the routing number, you must click the appropriate bank from the drop-down list presented. Doing so will automatically populate the Bank Name field. Please note that the Bank Name field is not a user editable field and is required to "Save & Continue." If you are unable to click the bank name from the drop-down list, you may also make your selection by using the down arrow on your keyboard and then press enter to make your selection.  

    Click "Save & Continue" to register the account. Click "Cancel" to return to the previous page without registering any account information. 

    Editing accounts

     For previously registered accounts, you must register the ending balance as of December 31, 2024. To do this, click either the "Edit Balance" or "Update Account Information" link for each registered account.

    Next, a pop-up will appear with your options, on  the "Edit Balance" tab, enter the required account ending balance as of December 31, 2024 and then click the "Save" button to register the information for the selected account. 

    Note: The ending balance entered must be the exact amount of the trust account bank balance as of December 31, 2024. 

    Note:

    • 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. 

    Click "Save" to register your updates. Click "Cancel" to return to the previous page. 

    Step 3: Self-Assessment 

    Step 3, if applicable, requires you to complete an annual self-assessment of client trust account management practices. Links to corresponding authorities and sources of information are provided for context.

    Note: If you are a subordinate attorney in a firm with some but not all of the responsibilities for complying with rule 1.15 of the Rules of Professional Conduct, then one or more of your responses to this self-assessment may be provided based on information you have received from a supervising attorney (see rules 5.1 and 5.2 of the Rules of Professional Conduct). 

    The self-assessment questions are divided across two pages. Click "Next" to save your page 1 responses and proceed to the second page.

    Once you have responded to all the self-assessment question, click "Save & Continue" to proceed. 

    Step 4: Annual Certification

    Step 4, if applicable, requires that you certify with the State Bar that you understand and comply with requirements and prohibitions applicable to the safekeeping of funds and property of clients and other persons, including rules 1.4, 1.5, and 1.15 of the Rules of Professional Conduct and selected Business and Professions Code sections. Select the applicable statement.

    Click "Cancel" to return to the previous page. Click "Save & Continue" to save your progress and continue to the next step. 

    Final Step: Annual Declaration

    The Final Step, requires that you submit the annual declaration. Check the box declaring under penalty of perjury that you personally completed the reporting requirements and enable the "Submit" button. 

    Click "Submit" to complete your CTAPP reporting requirements.

    Note: If the required accounts based on your Step 1 responses are not registered, you will not be able to submit the Final Declaration. Please return to Step 1 to review your responses and Step 2 to verify the registered accounts.

    Questions? Contact us.