What California Attorneys Should Know About the CTAPP Compliance Review Process

California’s Client Trust Account Protection Program (CTAPP) represents an important effort by the state bar to strengthen public protection and reinforce the proper handling of client trust funds. While annual CTAPP reporting requirements apply to most practicing attorneys, new requirements require a smaller group to be selected each year for a CTAPP compliance review performed by a California State Bar‑approved CPA firm.

Because this process is still relatively new, many attorneys and law firm administrators are unsure what a compliance review involves and how to prepare. If your firm is selected for compliance review, clear, practical guidance can help understand the process and make the experience more efficient.

What Is the CTAPP Compliance Review?

A CTAPP compliance review is an agreed‑upon procedures engagement focused on evaluating the accuracy, completeness and timeliness of your client trust accounting records. The California State Bar defines the exact procedures CPA firms must perform, and all reviews are conducted through the association’s secure audit management system.

The review is not an audit, and it does not provide an opinion. Instead, it documents factual findings that help ensure attorneys are following the requirements outlined by the state.

What Happens if You’re Selected

If selected for a CTAPP compliance review, you can expect the following steps:

1. Notification from the state bar

You’ll receive communication from the state bar with instructions and a secure portal for initial document uploads.

2. Initial records request

You’ll provide foundational trust accounting records, such as client ledgers, bank statements and reconciliations.

3. Select your CPA firm

From the approved list, you will select a CPA firm to perform the review. Weaver is one of the firms authorized to conduct these engagements.

4. Secondary records request

Your CPA firm will then issue a follow‑up request (records request #2) for more detailed materials needed to complete the engagement.

5. Fieldwork and testing

Your CTAPP team will complete the required procedures, including sampling trust account transactions, evaluating supervisory controls and reviewing reconciliation practices.

6. Reporting

Results of the engagement are submitted to the state bar, who then discusses the findings and any next steps with you.

What You Can Do Now to Prepare

Even if you are not currently selected, taking these steps now can help your firm be ready and reduce challenges or delays:

1. Maintain complete and accurate trust accounting records

Ensure your trust account documentation includes:

• Monthly three‑way reconciliations
• Detailed client ledgers
• Trust account journals
• Bank statements and cleared checks
• Fee agreements, settlement statements and other supporting documentation

2. Strengthen internal oversight

Documentation is paramount to the financial management of client trust accounts. Designated attorneys should be able to demonstrate clear oversight of trust accounting activity. If non‑attorneys or junior staff assist with bookkeeping, ensure policies and supervision are well‑documented.

3. Review your CTAPP annual reporting for accuracy

Confirm proper registration of Interest on Lawyers’ Trust Accounts (IOLTA) and non‑IOLTA accounts and ensure your self‑assessment responses reflect actual practices.

4. Establish consistent workflows and controls

Firms with defined processes, timely reconciliations and regular internal reviews are often better prepared for the structured nature of a CTAPP compliance review.

Supporting Your Firm Through the Review Process

CTAPP compliance reviews are designed to support attorneys in maintaining strong trust accounting practices, not to create unnecessary burden. At Weaver, we take an education‑forward approach, helping attorneys navigate the process with confidence and clarity.

As an approved provider of CTAPP compliance services, Weaver performs these reviews in alignment with the bar’s required methodology, confidentiality expectations and reporting standards. Peter Lee and Jennifer Dang lead Weaver’s CTAPP compliance review engagements and work directly with California attorneys to complete these procedures efficiently and in accordance with state bar requirements. Contact us if your firm has been selected for a review or would like to better understand how to prepare.

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