To comply with the Client Trust Account Protection Program (CTAPP) reporting requirements, click the "Client Trust Accounts (both IOLTA and Non-IOLTA)" link in your profile menu.
Under the "Client Trust Accounts (both IOLTA and Non-IOLTA)" heading, click the "CTAPP Annual Reporting" link to complete your CTAPP reporting requirements.
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 account(s)
- Complete self-assessment
- Submit annual certification
- Submit the final 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, IOLTAs and/or non-IOLTAs during the reporting period. Select applicable options and click "Next" to continue.
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 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: Account Registration
Step 2, if applicable, requires that you register accounts maintained during the reporting period.
Note: Registering accounts entails registering new accounts maintained during the reporting period and/or registering the ending balance for previously reported accounts.
- To add new accounts, click the "Add Account" button.
- To register the required account ending balance for a previously registered account, click the "Edit" link for each account.
Note: If your firm or organization maintains accounts on your behalf, they will be able to provide the required account information through the State Bar’s Agency Billing application. However, it is your responsibility to make sure your firm reports this information on your behalf.
Note: If you indicated in Step 1 that a firm or organization you no longer employed with maintained 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 accounts on your behalf.
Adding accounts
To add a new IOLTA, non-CA IOLTA, and/or non-IOLTA account, you must:
- Select the account type (IOLTA, non-CA IOLTA, or non-IOLTA).
- Enter the firm name or organization associated with the account.
- Enter the account routing number.
- Enter the account number.
- Enter the account ending balance as of December 31, 2023.
- Enter the date the account was opened.
- 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 and 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.
- 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, 2023 prior to submitting your final declaration.
Click "Save and Continue" to register the account. Click "Back" to return to the previous page without registering any information.
Editing accounts
For previously registered accounts, you are required to register the ending balance as of December 31, 2023. To register the ending balance, click the "Edit" link for each registered account.
Next, enter the required account ending balance as of December 31, 2023 and then click the "Save Changes" 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, 2023.
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 Changes" to register your updates. Click "Back" 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.
Respond to the 12 self-assessment questions and then click "Next" to proceed.
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 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 Annual Client Trust Account Reporting Declaration" button.
Click "Submit Annual Client Trust Account Reporting Declaration" to complete your CTAPP reporting requirements.
Note: The "Submit Annual Client Trust Account Reporting Declaration" button will not be enabled until you complete all reporting requirements. If the button is not enabled, review what is missing and click "Back" to review and complete missing items. 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.
Questions? Contact CTAPP@calbar.ca.gov.