The 14 CTAPP self-assessment questions, answered

What the self-assessment actually is

Every year, California attorneys who hold client funds complete the State Bar's Client Trust Account Protection Program requirements: registration of trust accounts, a self-assessment of how those accounts are managed, and a certification of compliance with rule 1.15. The reporting deadline is March 30. The form is short. The substance behind it is not.

Read closely, the self-assessment asks fourteen practical questions. Each one is a yes-or-no about a specific habit or control. This article walks through all fourteen in plain English: what each is really asking, and what a good answer requires you to have in place.

The first seven: do you know where the money is

Questions one through seven are about knowledge: whether the firm can say, at any moment, whose money it holds and whether the records agree.

• 1. Can you list every client balance by matter, right now? A good answer is a report you can run today, not a spreadsheet someone maintains when they remember to.
• 2. Do those balances match the bank? The total of all client ledgers must equal the trust bank balance to the penny, not approximately.
• 3–4. Was a three-way reconciliation done for each of the last three months, and can you show who did it and when? The bar is asking for evidence of routine, not a one-time cleanup.
• 5. Do you know your reconciliation obligations and are you meeting them? Monthly reconciliation is the standard the rules assume.
• 6–7. Does trust money ever touch the operating account, and are bank charges paid from operating? Commingling, even brief or accidental, is the single most common thread in trust discipline cases.

The last seven: does the system work without heroics

Questions eight through fourteen are about durability: whether the firm's habits hold up when nobody is watching.

• 8. When a matter closes, does the remaining client balance go out within the required timeline? Old balances sitting in trust are a finding waiting to be written down.
• 9. Are stale outstanding checks identified and resolved? A check that never clears is money that belongs to someone.
• 10. Does one person both move money and record it? Segregation of duties is hard in a small firm. That is exactly why an outside monthly reviewer matters. We hold ourselves to the same logic: your firm moves the money, we reconcile it, and every reconciliation carries a named reviewer's signature.
• 11. Could you reconstruct any single trust transaction from last year, end to end? This is the test of documentation, not memory.
• 12. Are retainers moved to operating only as fees are earned? Earned-on-receipt handling must match your engagement terms and the rules.
• 13. If the bar asked for your trust records tomorrow, could you hand them over without a cleanup project? Answer honestly. This question is the whole program in one sentence.
• 14. Do you know, today, whether you would pass? If the answer is “I think so,” that is the finding.

What a good score looks like

One note first: this scoring is ours, drawn from practice, not the bar's. Twelve or more confident yeses means your records are in genuine order. Eight to eleven means drift: correctable, but worth correcting before the next cycle rather than during it. Fewer than eight means the account is running on hope, and hope is not a control.

The self-assessment is due every year whether your records are ready or not. The firms that find it routine are not smarter. They reconcile every month, so the annual questions answer themselves.