Client Trust Account (IOLTA) Reconciliation - Colorado

CLIENT TRUST ACCOUNT (IOLTA / COLTAF) RECONCILIATION — COLORADO

Account and Period Information

I. Purpose and Governing Rule

This reconciliation documents compliance with the Colorado Rules of Professional Conduct governing safekeeping of client and third-party property:

• Colo. RPC 1.15A — duty to hold client/third-party property separate and to keep complete records (per Rule 1.15D).
• Colo. RPC 1.15B — trust account requirements; a pooled trust account for nominal/short-term funds is a COLTAF Trust Account, with interest/dividends remitted to the Colorado Lawyer Trust Account Foundation.
• Colo. RPC 1.15C(c) — no less than quarterly, a lawyer (or supervised person) shall reconcile the trust account records both as to individual clients/persons and in the aggregate against the bank statements. Monthly reconciliation is recommended.
• Colo. RPC 1.15D — required records must be maintained currently and retained for seven (7) years after the event recorded.
• Colo. RPC 1.15E — trust accounts must be held at a financial institution approved by the Office of Attorney Regulation Counsel that has agreed to report overdrafts/insufficient-funds instruments to Regulation Counsel.

Colorado lawyers must certify annual compliance with Rule 1.15 (or explain non-compliance) on the Attorney Registration Statement.

II. Three-Way Reconciliation Summary

All three balances below must agree as of the period-end date. Record the result in the final line.

A. Adjusted Bank Balance

B. Checkbook / Control (Book) Balance

C. Sum of Client Ledger Balances (Trial Balance)

D. Agreement Check

Reconciled amount (if all agree): $[____]

III. Client Ledger Schedule

IV. Exception and Variance Investigation

Complete only if the three balances do not agree or if any red flag below is present.

Variance amount: $[____]

Potential causes reviewed:

☐ Bank error (contact institution)
☐ Unrecorded deposit or disbursement
☐ Duplicate or transposed entry
☐ Math error on a client ledger
☐ Posted bank service charge / interest not recorded
☐ Outstanding check more than six months old
☐ Negative (overdrawn) client ledger balance
☐ Unidentified funds in the account
☐ Other: [________________________________]

Investigation notes:

[____________________________________________________________]

[____________________________________________________________]

Resolution:

☐ Variance resolved — corrective action: [________________________________]
☐ Variance unresolved — escalation required

Date resolved: [__/__/____] Resolved by: [________________________________]

V. Compliance Checklist (Colo. RPC 1.15A–1.15E)

☐ Client/third-party funds are held separate from business, personal, and other fiduciary funds; no commingling (RPC 1.15A(a), 1.15B(a))
☐ Only a Colorado lawyer or a supervised person is an authorized signatory; no debit/ATM cards, no checks payable to "Cash," no cash withdrawals (RPC 1.15C(a)–(b))
☐ No negative client ledger balances — no client's funds used for another client
☐ Earned fees and reimbursed costs withdrawn promptly once earned/incurred; no lawyer funds left in the account beyond reasonable bank-charge cushion (RPC 1.15B(f))
☐ Account is held at a Regulation Counsel-approved institution that reports overdrafts/insufficient-funds instruments (RPC 1.15D/1.15E)
☐ Nominal/short-term funds held in a COLTAF Trust Account; interest/dividends remitted to COLTAF (RPC 1.15B(b),(g))
☐ Reconciliation performed no less than quarterly, individually and in the aggregate (RPC 1.15C(c)); monthly recommended
☐ Required records maintained currently and retained seven (7) years (RPC 1.15D(a))
☐ Outstanding checks older than six months investigated; replacement issued as appropriate
☐ Annual Rule 1.15 compliance certification made on the Attorney Registration Statement
☐ Prior-period reconciliations on file and available for review under C.R.C.P. 251

VI. Preparer and Reviewing-Attorney Certification

I certify that this reconciliation was performed in accordance with Colo. RPC 1.15A–1.15E, that all client and third-party funds are accounted for, that no funds have been converted or misappropriated, and that supporting records will be retained for at least seven years.

Preparer

Signature: ________________________________ Date: [__/__/____]

Printed name / title: [________________________________]

Reviewing Attorney

Signature: ________________________________ Date: [__/__/____]

Printed name / Attorney Reg. No.: [________________________________]

Colorado Practice Notes

• Trust-accounting rule: Colo. RPC 1.15A–1.15E (Rule 1.15 was repealed and readopted as Rules 1.15A–1.15E effective June 17, 2014).
• Reconciliation frequency: No less than quarterly, both individually (per client) and in the aggregate, against bank statements (RPC 1.15C(c)). Monthly is the recommended practice.
• Retention: Seven (7) years after the event the record reflects (RPC 1.15D(a)).
• IOLTA program: Colorado Lawyer Trust Account Foundation (COLTAF). Pooled nominal/short-term funds go in a "COLTAF Trust Account"; interest belongs to COLTAF.
• Overdraft notification / self-audit: Trust accounts must be at an institution approved by the Office of Attorney Regulation Counsel that reports any properly payable instrument presented against insufficient funds, whether or not honored (RPC 1.15E(c)). Annual self-certification of Rule 1.15 compliance is made on the Attorney Registration Statement.
• Unsettled / verify: Colorado sets a quarterly minimum but does not prescribe a single mandatory reconciliation form; confirm current COLTAF rate-comparability and approved-institution lists with Regulation Counsel before relying on this worksheet.

Sources and References

• Colo. RPC 1.15A–1.15E (Office of Attorney Regulation Counsel PDF)
• Colorado Rules of Professional Conduct (COBAR full text)
• Rule 1.15C — Use of Trust Accounts (COBAR)
• Rule 1.15D — Required Records (COBAR)
• Office of Attorney Regulation Counsel — Basic Requirements for Trust Accounts
• Colorado Lawyer Trust Account Foundation (COLTAF)