The CTAPP packet, ready when the reviewer asks.

What CTAPP asks of California lawyers

The Client Trust Account Protection Program is the State Bar of California's framework for trust accounts. In summary:

• Every client trust account, including IOLTA accounts, is registered each year.
• Each account has a designated licensee, who is responsible for performing or supervising the monthly reconciliation.
• Lawyers complete an annual self-assessment and certify compliance with Rule 1.15.
• The State Bar selects firms for compliance reviews, carried out by approved CPAs, that look at at least a year of trust activity. Records are due within a set deadline, and incomplete records make a review longer.

What the LawMOR packet contains

1. Trust account inventoryBank, last four digits, IOLTA status, designated licensee and license number, open and close dates, and the date the State Bar notice went to the bank.
2. Monthly three-way reconciliationsEvery signed reconciliation in the period, with outstanding deposits and checks, showing a difference of zero.
3. Trust journalAccount-level record of every deposit and disbursement with a running balance.
4. Client ledgersEvery client and matter with activity or a balance in the period, with opening, running and closing balances.
5. Deposit records and receipt noticesDate, amount, payor, method and ledger for each deposit, plus the log of client notices with the date and channel each was sent.
6. Disbursements and transfersCheck or reference number, payee, purpose and ledger for each disbursement, and every transfer to operating with the invoice it paid.
7. Bank statements and check imagesThe statements and cancelled-check references you uploaded for the period.
8. Fee agreements and invoices indexLinks to the engagement letters and invoices for matters with trust activity.
9. Interest and bank-charge activityIOLTA interest and the small firm float kept for bank charges.
10. Self-assessment checklist and manifestAnswers pre-filled from your records, plus a manifest listing every file with its hash.

The packet also includes an exceptions page, so you see problems before the reviewer does: months without a signed reconciliation, ledgers that went negative in imported history, items uncleared for more than 90 days, and deposits without a receipt notice.

Why the records hold up

• A client ledger can never go below zero; the database refuses it.
• Trust transactions are never edited or deleted. Mistakes are corrected with reversing entries.
• Transfers to operating require an issued invoice and an available balance.
• Only the designated licensee, after confirming their second factor, can sign a reconciliation, and only when the difference is $0.00.
• Signed reconciliations and packets are stored with a hash, so any later change is detectable.

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