The framework
ABA Model Rule 1.15, Safekeeping Property, is the template. It requires client funds to be held separately from the lawyer’s own, complete records to be kept, and those records to be preserved.
The Model Rule is not binding on its own. Nearly every state has adopted a version of it, most have added requirements on top, and Texas numbers its version Rule 1.14. The additions are where the practical detail sits: how often to reconcile, which banks qualify, what format the records take, and how long to keep them.
On frequency, the ABA’s model record-keeping rules set quarterly as the minimum and describe monthly as preferable, and many states require monthly outright. Monthly also keeps any discrepancy traceable to a single month of activity rather than ninety days of it.
This page describes what the books need to show. The rule that binds you is your own state’s version of Rule 1.15, and your state bar is the authority on it. Read that alongside this.
What it proves
A three-way reconciliation confirms that three independently kept records agree, to the cent, on the same date.
| Balance | Source | What it proves |
|---|---|---|
| 1. Adjusted bank balance | The trust bank statement, adjusted for outstanding deposits and disbursements | What the bank actually holds |
| 2. Trust account journal | The running record of every trust transaction | What the firm recorded |
| 3. Sum of client ledgers | The total of every individual client or matter balance | That the money is attributed to the right people |
A two-way reconciliation, bank against journal, is what most businesses do and it is not enough here. It can balance perfectly while one client’s money quietly covers another’s shortfall. Only the third leg catches that, which is why it is the one regulators look for.
The evidence
The State Bar of California’s monthly reconciliation form lists what must be attached for each trust account. It is the clearest published statement of what the books have to produce, and a useful standard wherever you practise.
| # | Document | What it must show |
|---|---|---|
| 1 | Account journal | Every deposit and disbursement for the account, in date order, with a running balance |
| 2 | Individual client ledgers | Every transaction for one client, with that client’s running balance |
| 3 | Bank statement with check copies | The external record the other two are proved against |
| 4 | Client ledger summary with balances | Every client’s balance on one page, totalled |
| 5 | List of outstanding deposits | Money recorded but not yet cleared by the bank |
| 6 | List of outstanding disbursements | Checks and payments issued but not yet cleared |
Documents 5 and 6 are how the bank balance becomes an adjusted bank balance. Document 4 is the third leg. If a firm cannot produce document 4 in a few minutes, it is not performing a three-way reconciliation, whatever it calls the process.
The detail
A reconciliation is only as good as the entries it adds up. California’s standard requires each journal entry to show five things.
A trust account that records disbursements only at the account level, without a ledger per client or matter, does not meet the requirement in any jurisdiction following Rule 1.15. Matter-level accounting is the baseline, not an enhancement.
Costs the firm fronts and expects to recover, filing fees, expert fees, court reporters, are neither trust liabilities nor ordinary firm expenses. Track them as their own asset. Blending them into either distorts the reconciliation, because a cost paid from operating and recovered into trust moves between two accounts that must never be confused.
The failure modes
Three bookkeeping errors carry disciplinary weight regardless of intent. Each is preventable by the books rather than caught by them.
A disbursement processed against the wrong matter, or a payment made before the settlement deposit it depends on has cleared. For that moment, one client’s funds paid another client’s obligation. The account total can be positive while an individual ledger is negative, which is exactly why the third leg exists.
Prevention is at the point of entry: no disbursement against a matter whose ledger will not cover it, and no payment against uncleared funds.
Firm money in trust, or trust money in operating. Earned fees left in the trust account longer than the rule permits count, even though the money genuinely belongs to the firm. So does paying a firm expense directly from trust.
Rule 1.15 requires client funds to be delivered promptly once they are due and any valid holds, such as liens, are resolved. No state sets a day count, and examiners treat funds sitting for months past the point they could have been distributed as a potential violation. An aging report on trust balances surfaces these; a reconciliation that only checks totals does not.
The pattern in audited firms is consistent: a disbursement against the wrong matter, or a payment ahead of the deposit it relied on, not caught until month end. Month end is too late, because by then the violation has already happened. The reconciliation proves the books; the controls on entry keep them clean.
The account types
| Account | Used for | Interest goes to |
|---|---|---|
| IOLTA | Pooled funds that are nominal in amount or held briefly | The state IOLTA program |
| Non-IOLTA trust | A single client’s funds where the amount or holding period justifies earning interest for them | The client |
Both types are trust accounts, both need the same three-way reconciliation, and both fall within the same reporting obligations. The difference is only where the interest goes.
In California, Rule 1.15(b) allows an advance flat fee to go into the operating account, but only after written disclosures to the client, and a flat fee over $1,000 also requires the client’s signed agreement. Without both, it belongs in trust until earned. Other states treat advance fees differently. Where the paperwork is not in place, running the fee through trust is the safe default.
The architecture
A law firm’s trust accounting sits across two systems, and each owns a different part of the record.
The design choice that matters is keeping the trust bank account completely separate in Xero, with its own feed, never touched by operating transactions. The firm’s books then show the trust obligation clearly as a liability, and the reconciliation against the practice management system has one clean number to meet.
More on how this fits a law firm’s wider books is in Law Firms .
For California firms
California’s trust rules changed more in the last three years than in the previous thirty.
They sit in three places: Business and Professions Code sections 6210 to 6228, Rule of Professional Conduct 1.15, and the annual Client Trust Account Protection Program. The State Bar launched CTAPP in 2023, following the Tom Girardi case, and it requires nearly every actively licensed attorney to register trust accounts and complete a self-assessment every year, including attorneys who hold no client funds and must certify that instead.
The enforcement is real. In July 2023 the State Bar administratively suspended more than 1,600 attorneys for failing to comply with the new reporting requirements. That was over paperwork, before any question of what the reconciliations contained.
Retention outside California is commonly five to seven years depending on the state, and it covers the reconciliations themselves, not only the statements and ledgers behind them.
Questions