Client Trust Account (IOLTA) Reconciliation - District of Columbia

CLIENT TRUST ACCOUNT (DC IOLTA) RECONCILIATION — DISTRICT OF COLUMBIA

Account and Period Information

I. Purpose and Governing Rule

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

• D.C. R. Prof'l Conduct 1.15(a) — client/third-party property held separate; complete records kept and preserved for five (5) years after termination of the representation.
• D.C. R. Prof'l Conduct 1.15(b) — all trust funds deposited with an "approved depository" under Rule XI; nominal/short-term funds must be held in compliance with the DC IOLTA program. Each DC IOLTA account title must include the lawyer/firm name and "DC IOLTA Account" or "IOLTA Account"; other trust accounts must say "Trust Account" or "Escrow Account."
• D.C. R. Prof'l Conduct 1.15(e) — advances of unearned fees and unincurred costs are client property held in trust until earned or incurred.
• D.C. R. Prof'l Conduct 1.15(f) — only a small amount of the lawyer's own funds may be placed in trust to defray bank charges.
• D.C. R. Prof'l Conduct 1.19 and Rule XI, § 20 — approved-depository and overdraft-notification framework supporting the DC IOLTA program; interest is remitted to the D.C. Bar Foundation.

D.C. does not prescribe a numeric reconciliation interval in the black-letter rule; monthly three-way reconciliation is the recognized best practice for satisfying the Rule 1.15(a) "complete records" duty.

II. Three-Way Reconciliation Summary

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

A. Adjusted Bank Balance

B. Checkbook / Trust Journal (Control) Balance

C. 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 (D.C. R. Prof'l Conduct 1.15, 1.19)

☐ Client/third-party funds held separate from the lawyer's own property; no commingling (RPC 1.15(a))
☐ Only the lawyer's funds necessary to defray bank charges are placed in trust (RPC 1.15(f))
☐ No negative client ledger balances — no client's funds used for another client
☐ Advances of unearned fees / unincurred costs held in trust until earned or incurred (RPC 1.15(e))
☐ Earned fees withdrawn promptly once earned; client promptly notified and paid amounts due (RPC 1.15(c))
☐ Funds held at a Rule XI approved depository; nominal/short-term funds in a DC IOLTA account (RPC 1.15(b); Rule XI § 20) — DC lawyers cannot opt out of IOLTA
☐ Account title includes lawyer/firm name and "DC IOLTA Account" or "IOLTA Account" (RPC 1.15(b))
☐ DC IOLTA account bears the D.C. Bar Foundation TIN (52-1109547) — not the lawyer's/firm's TIN
☐ Complete records maintained and retained five (5) years after termination of the representation (RPC 1.15(a))
☐ Approved depository participates in the overdraft-notification program (RPC 1.19; Rule XI § 20)
☐ Three-way reconciliation (bank / journal / client ledgers) performed — monthly recommended
☐ Prior-period reconciliations on file

VI. Preparer and Reviewing-Attorney Certification

I certify that this reconciliation was performed in accordance with D.C. R. Prof'l Conduct 1.15 and 1.19 and Rule XI, § 20, 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 five years.

Preparer

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

Printed name / title: [________________________________]

Reviewing Attorney

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

Printed name / D.C. Bar No.: [________________________________]

District of Columbia Practice Notes

• Trust-accounting rule: D.C. R. Prof'l Conduct 1.15 (safekeeping property) and 1.19, implemented by D.C. Court of Appeals Rule XI, § 20 (approved depositories; IOLTA).
• Reconciliation frequency: No numeric interval in the black-letter rule; monthly three-way reconciliation is the recognized best practice to satisfy the Rule 1.15(a) duty to keep "complete records."
• Retention: Five (5) years after termination of the representation (RPC 1.15(a)).
• IOLTA program: Administered by the D.C. Bar Foundation. Since the August 2010 rule revision, DC lawyers can no longer opt out of IOLTA; nominal/short-term funds must be held in a DC IOLTA account at an approved depository. All DC IOLTA accounts bear the Foundation's TIN (52-1109547).
• Overdraft notification / self-audit: Approved depositories must report overdrafts/dishonored instruments under the Rule XI / Rule 1.19 framework. D.C. has no annual trust-accounting certificate analogous to Florida's or Delaware's; oversight runs through Disciplinary Counsel and the approved-depository reporting system.
• Reciprocity note: Under RPC 1.15(b), a lawyer compliant with the trust-accounting rules and IOLTA program of the jurisdiction in which the lawyer is licensed and principally practices may be excused from certain DC-specific account requirements — confirm before relying on an out-of-jurisdiction account.
• Unsettled / verify: Confirm the current approved-depository list and any benchmark IOLTA rate with the D.C. Bar Foundation before relying on this worksheet.

Sources and References

• D.C. R. Prof'l Conduct 1.15 — Safekeeping Property (D.C. Bar)
• D.C. Bar Foundation — IOLTA Rules (Rule 1.15, Rule XI § 20)
• D.C. Court of Appeals Rule XI — Disciplinary Proceedings (D.C. Bar)
• D.C. Bar — Rules of Professional Conduct Review Committee IOLTA Report (Rules 1.15 and 1.19)