Client Trust Account (IOLTA) Reconciliation - Connecticut

CLIENT TRUST ACCOUNT (IOLTA / IOTA) RECONCILIATION — CONNECTICUT

Account and Period Information

I. Purpose and Governing Rule

This reconciliation documents compliance with the Connecticut rules governing safekeeping of client and third-party funds:

• Conn. RPC 1.15(b), (i) — funds must be held in a trust account; lawyers and law firms must participate in the statutory IOLTA program (Conn. Gen. Stat. § 51-81c).
• Conn. RPC 1.15(j) — lists the basic financial records (checkbook registers, bank statements, records of deposit, prenumbered canceled checks, substitute checks, electronic transfer records, individual client ledgers) that must be maintained for at least seven years after termination of each engagement.
• Conn. RPC 1.15 commentary — the trial balance (sum of each client ledger) is compared monthly to a control balance (prior balance + receipts − disbursements); once the totals match, the reconciliation to the bank statement follows by adding outstanding deposits and subtracting outstanding checks. Quarterly reconciliation is the minimum; monthly is preferred.
• Practice Book § 2-27 — records of the maintenance and disposition of client/third-party funds must be kept and retained seven years; each lawyer must annually register every clients'-funds account and identification number.
• Practice Book § 2-28 — approved depositories and the overdraft notification program (§ 2-28(f) triggers Statewide Grievance Committee review of records).

II. Three-Way Reconciliation Summary

All three balances below must agree as of the period-end date.

A. Adjusted Bank Balance

B. Control (Checkbook) Balance

C. Trial Balance (Sum of Client Ledger Balances)

D. Agreement Check

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

III. Client Ledger Schedule

IV. Exception and Variance Investigation

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
☐ Stale outstanding check (investigate)
☐ 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 (Conn. RPC 1.15; P.B. §§ 2-27, 2-28)

☐ Client/third-party funds held separate from the lawyer's or firm's personal and operating funds; no commingling (RPC 1.15(b); P.B. § 2-27(a))
☐ No negative client ledger balances — no client's funds used for another client
☐ Earned fees and reimbursed costs withdrawn promptly once earned/incurred
☐ Records required by RPC 1.15(j) maintained and retained seven (7) years after termination of each engagement (RPC 1.15(j); P.B. § 2-27(b))
☐ All client electronic funds transfers recorded; no check number reused for an electronic transfer (RPC 1.15(j)(8))
☐ Account held at a CT-authorized depository participating in the overdraft notification program (P.B. § 2-28); records available to the Statewide Grievance Committee on an overdraft notice (P.B. § 2-27(c), § 2-28(f))
☐ Firm enrolled in IOLTA/IOTA with the Connecticut Bar Foundation; nominal/short-term funds pooled; interest remitted to CBF (RPC 1.15(i); CGS § 51-81c)
☐ Each clients'-funds account and identification number registered annually with the Statewide Grievance Committee (P.B. § 2-27(d))
☐ Trial balance compared to control balance and bank statement at least quarterly (monthly preferred) (RPC 1.15 commentary)
☐ Prior-period reconciliations on file

VI. Preparer and Reviewing-Attorney Certification

I certify that this reconciliation was performed in accordance with Conn. RPC 1.15 and Practice Book §§ 2-27 and 2-28, 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 / Juris No.: [________________________________]

Connecticut Practice Notes

• Trust-accounting rule: Conn. RPC 1.15, implemented by Connecticut Practice Book §§ 2-27 and 2-28 and Conn. Gen. Stat. § 51-81c.
• Reconciliation frequency: Quarterly is the minimum; monthly is the preferred practice (RPC 1.15 commentary). The trial balance (sum of client ledgers) is compared to the control balance and then to the bank statement.
• Retention: Seven (7) years after termination of each engagement (RPC 1.15(j); P.B. § 2-27(b)).
• IOLTA program: Connecticut Bar Foundation administers the IOLTA/IOTA program; participation is mandatory for lawyers/firms holding qualifying client funds (RPC 1.15(i)).
• Overdraft notification / self-audit: Approved depositories report dishonored/insufficient-funds instruments; an overdraft notice under P.B. § 2-28(f) authorizes the Statewide Grievance Committee or disciplinary counsel to review, examine, or audit the records (P.B. § 2-27(c)).
• Unsettled / verify: Connecticut does not mandate a single official reconciliation form; the "quarterly minimum / monthly preferred" standard comes from the Rule 1.15 commentary rather than a numeric mandate in the black-letter rule. Confirm current account-registration and IOLTA enrollment requirements with the Statewide Grievance Committee and Connecticut Bar Foundation.

Sources and References

• Conn. RPC 1.15 (Connecticut Practice Book, jud.ct.gov)
• Conn. Practice Book § 2-27 — Clients' Funds; Attorney Registration
• Conn. Practice Book § 2-28 — Approved depositories; overdraft notification
• Conn. Gen. Stat. § 51-81c (IOLTA)
• Connecticut Bar Foundation — IOLTA/IOTA Bank Resources
• Connecticut Bar Association — What You Need to Know about IOLTA