To comply with the Client Trust Account Protection Program (CTAPP) reporting requirements, click the "CTA (including IOLTA)" link in the reminder located at the top your profile or click the "Client Trust Accounts (including IOLTA)" link in your profile menu.
Under the "Client Trust Accounts (including IOLTA)" heading, click "Go to CTA (including IOLTA)" to report your compliance with the CTAPP reporting requirements.
Please note: Your current CTAPP compliance status is indicated in your profile.
Follow the steps below to satisfy the CTAPP reporting requirements:
- Respond to reporting questions
- Register CTAs
- Complete self-assessment
- Submit annual CTA certification
- Submit the CTA declaration to complete the reporting process
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, CTAs or IOLTAs during the reporting period. Select applicable options and click "Next" to continue.
Please note: Your reporting progress is saved after clicking the "Save and Continue" buttons available throughout the reporting process. Click "Save and Continue" to save your progress and return at a later time to complete all your CTAPP reporting requirements.
After clicking "Next", you will be asked to review your responses. Click "Back" to modify your responses. Click "Save and Continue" to save your progress and continue to the next step.
Step 2: CTA Account Registration
Step 2, if applicable, requires that you register CTAs (including IOLTAs) maintained during the reporting period.
- To add individual CTA and/or non-California IOLTA information, click the "Add Indiv. CTA and non-CA IOLTA" button.
- To add California IOLTA information, click the "Add CA IOLTA" button.
Please note: If your firm or organization maintains CTAs on your behalf, they will be able to provide the account information through the State Bar’s Agency Billing application. However, it is your obligation to make sure your firm reports this information on your behalf. Regardless of whether your firm registers the accounts on your behalf, you must complete all other reporting requirements through your My State Bar Profile.
Please note: If you indicated in Step 1 that a firm or organization you no longer employed with maintained IOLTA or CTA accounts on your behalf select the "Other" option and specify again in the text box field that a firm or organization you are no longer employed with maintained IOLTA and/or CTA accounts on your behalf.
Adding individual CTA or non-California IOLTA
When adding individual CTA or non-California IOLTA information, you are required to provide:
- Routing number
- Bank name
- Account number
- Account ending balance as of December 31, 2022 or the date the account was closed
- Date the individual CTA or non-California IOLTA was opened
- State account is held
Please note: Please enter the account routing number first. When entering your account 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, the Bank Name field is not a user editable field and is required to "Save and Continue."
Click "Save and Continue" to submit the account information. Click "Back" to return to the previous page without submitting any information.
Adding California IOLTA
When adding California IOLTA information, you are required to provide:
- Routing number
- Bank name
- Account number
- Account ending balance as of December 31, 2022 or the date the account was closed
Please note: Please enter the account routing number first. When entering your account 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, the Bank Name field is not a user editable field and is required to "Save and Continue."
Click "Submit" to submit the account information. Click "Back" to return to the previous page without submitting any information.
All reported CTA information will display in the table on the "Step 2: Account Registration" page.
Please note: If you need to edit the account information displayed in the table, you must click the "Remove" option to delete the account information entirely and then re-enter the account information as new by selecting either the "Add Indiv. CTA and non-CA IOLTA" or "Add CA IOLTA" button.
Click "Back" to return to the previous page. Click "Save and Continue" to save your progress and continue to the next step.
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.
Respond to the 12 self-assessment questions and then click "Next" to proceed.
Please 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).
After clicking "Next", you will be asked to review your responses. Click "Back" to modify your responses. Click "Save and Continue" to save your progress and continue to the next step.
Step 4: CTA 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 "Back" to return to the previous page. Click "Save and Continue" to save your progress and continue to the next step.
Final Step: Annual CTA Declaration
The Final Step, requires that you submit the annual CTA declaration.
Please note: The final "Submit Annual Client Trust Account Reporting Declaration" will not be enabled until you complete all reporting requirements. If the button is not enabled, click "Back" to review and complete missing reporting requirements. You may also click "Return to My State Bar Profile" to save your progress and return at a later time to complete all your CTAPP reporting requirements.
Click "Submit Annual Client Trust Account Reporting Declaration" to complete your CTAPP reporting requirements.