California CTAPP · Rule 1.15 trust accounting

The CTAPP reviews are here. Organize the records a CTAPP review asks for.

In 2026 the State Bar randomly selected 400 California attorneys for a mandatory trust account review. If you are selected, you hire a State Bar approved CPA at your own expense, $10,000 to $25,000, and they examine your monthly three-way reconciliations, 14-day client notifications, and 45-day disbursements. IOLTAWatch runs those first three, automatically, so the records exist before anyone asks for them.

Bank-grade read-only connection Built around Rule 1.15 and CTAPP
What the CPA looks for

A CTAPP review checks the records. IOLTAWatch builds them every night.

The mandatory review covers your reconciliations, notification timing, disbursement timing, and recordkeeping under Rule 1.15. IOLTAWatch does not sit the exam for you. It keeps the underlying records current and flagged, so if you are selected you are producing a file, not reconstructing a year of history from bank statements.

What a review checks

The four record areas

  • Monthly three-way reconciliation: bank statement against your check register against the sum of individual client ledgers.
  • 14-day notification: clients and third parties told of received funds within 14 days.
  • 45-day disbursement: undisputed funds moved within the presumed-reasonable window.
  • Recordkeeping: individual client ledgers with every deposit, withdrawal, and running balance, retained five years.
What IOLTAWatch keeps in one place

The records, kept current

  • Automated nightly three-way reconciliation with an immediate alert the moment the three balances stop matching.
  • Every deposit carries a 14-day notification flag until you mark the client notified.
  • Matters with a balance and no activity since a deposit are flagged as 45-day idle funds.
  • Timestamped audit log and archived reconciliation PDFs, held for the five-year window.
The CTAPP calendar

California added a compliance layer no other state has. The dates are fixed.

CTAPP took effect December 1, 2022. It layers annual registration, a self-assessment, and a written certification on top of the Rule 1.15 duties every California attorney already carries. Miss the window and the consequence is not a fine, it is your status.

FEBRUARY 1

Three annual obligations come due

Register every trust account with the State Bar, complete the self-assessment against Rule 1.15, and certify compliance in writing. All three are due February 1, aligned with bar dues.

APRIL 1

Noncompliance moves you to inactive status

An attorney who has not met the CTAPP obligations by April 1 is moved to involuntary inactive status. Inactive means you cannot practice.

SEP 29, 2025

Mandatory compliance reviews launched

The State Bar launched mandatory trust account compliance reviews. This is enforcement with a CPA attached, not a self-reported checkbox.

2026

400 attorneys randomly selected

Selection is random, so a clean history is no protection. Each selected attorney hires a State Bar approved CPA at their own expense, $10,000 to $25,000 per review.

Rule 1.15  ·  Monthly three-way reconciliation, notification of received funds within 14 days, and a rebuttable presumption that 45 days is reasonable to distribute undisputed funds. Individual client ledgers retained five years.
The reconciliation portion is exactly what IOLTAWatch automates. Nightly three-way reconciliation, 14-day and 45-day flags, and an archived PDF for every period mean the reviewer sees a maintained record instead of a scramble.
How it works

Connect once. The record maintains itself.

You link the account one time. IOLTAWatch handles the nightly reconciliation, the deadline flags, and the PDF archive. There is no new accounting platform to learn and no IT lift.

01 / connect

Connect your trust account

Link your California IOLTA account through a bank-grade read-only connection in under two minutes. Read-only means we can see transactions and can never move money.

Setup time~ 2 min
02 / monitor

We reconcile and flag every night

Each deposit and disbursement is matched to the correct client sub-ledger. The three-way reconciliation runs nightly, and 14-day notification and 45-day idle-funds flags surface the moment a deadline is in play.

ReconciliationNightly
03 / archive

Keep the records organized year round

Reconciliation PDFs and a timestamped audit log are archived for the five-year retention window, and a CTAPP reminder lands before the February 1 deadline. If a review comes, the file already exists.

Retention5 years
Pricing

One price against a review that costs tens of thousands.

No tiers, no seat math, no surprise upgrade when you take on your fifteenth client matter. Cancel anytime, and your archived reconciliations stay yours.

California Trust Monitoring

IOLTAWatch

For solo and small California firms, 1 to 5 attorneys.

$ 199 / month, per firm

Billed monthly. 30-day money-back guarantee. Cancel anytime.

  • Automated nightly three-way reconciliation
  • 14-day client notification tracking on every deposit
  • 45-day idle-funds flags on untouched matters
  • Annual CTAPP reminder ahead of February 1
  • Responsible member designation (AB 3279)
  • Timestamped audit log and archived reconciliation PDFs
  • Unlimited client sub-ledgers and matters
Get started

Built around California Rule 1.15 and the CTAPP obligations.

What $199 actually buys you

Less than two billable hours a month, against a review priced at $10,000 to $25,000.

The math is not close. A single mandatory review, if you are one of the 400, costs more than a decade of IOLTAWatch. And the review goes better when the reconciliations, notifications, and disbursement timing were tracked all along instead of reconstructed under a deadline.

 
By hand
IOLTAWatch
Three-way reconciliation
Monthly, manual
Nightly, automatic
14-day notification
You remember
Flagged per deposit
45-day disbursement
You remember
Idle-funds flag
February 1 CTAPP
A calendar note
Reminder sent
If a review comes
Reconstruct
Produce the file

To be exact about the line: registration, the self-assessment, and the certification are filed by the attorney directly with the State Bar, and IOLTAWatch does not determine whether funds are disputed. IOLTAWatch tracks, flags, reminds, and keeps the records a reviewer requests in one place. The filing and the legal judgment stay with you.

Questions California attorneys ask

Straight answers before you sign up.

Does this make me CTAPP compliant?

No, and any product that promises that is overselling. CTAPP compliance means you registered your trust accounts, completed the self-assessment, and certified in writing to the State Bar, and it means your actual trust accounting follows Rule 1.15. Those filings are yours to make. What IOLTAWatch does is keep the underlying records (reconciliations, notification timing, disbursement timing) current and audit-ready, so the reconciliation portion of a review is a non-event and your February 1 self-assessment is grounded in real data.

What happens if I am one of the 400 attorneys selected in 2026?

You hire a State Bar approved CPA at your own expense, typically $10,000 to $25,000, and they examine your monthly three-way reconciliations, 14-day notifications, 45-day disbursements, and recordkeeping. IOLTAWatch does not replace that CPA. It means the records they ask for already exist, timestamped and archived, instead of being rebuilt from a year of bank statements.

Does IOLTAWatch file my CTAPP registration or certification for me?

No. Registration, the self-assessment, and the certification are filed by the attorney directly with the State Bar. IOLTAWatch sends you a reminder ahead of the February 1 deadline and keeps your reconciliation records ready, but it does not submit anything to the State Bar on your behalf.

How does the 45-day disbursement flag work if you cannot tell what is disputed?

Correct, we cannot, and we do not pretend to. IOLTAWatch flags any matter that still holds a balance and has had no ledger activity since a deposit, as a proxy for the 45-day clock. Whether those specific funds are undisputed and ready to distribute is a legal judgment only you can make. We surface the clock. You apply the judgment.

Is my banking connection safe?

The connection is bank-grade and read-only. IOLTAWatch can see transactions to build the reconciliation, and it can never move money. Your login credentials are never stored by us.