Every state writes its own trust-account rules. This matrix — the reference table from our handbook, Accounting Books for Attorneys — puts all 50 states and DC side by side: IOLTA status, how long records must be kept, whether a three-way reconciliation is expressly required, and whether your bank must report an overdraft to the bar.
Only four states let lawyers opt out: Alaska, Kansas, Nebraska, and Wyoming. Everywhere else, client funds that are nominal or short-term go into an IOLTA account — no exceptions for small firms.
5 years in 28 jurisdictions, 6 years in 14, 7 years in 9 (Colorado, Connecticut, Illinois, Mississippi, New Jersey, New York, Ohio, Rhode Island, Washington). The clock usually starts at the last disbursement or the event recorded.
In 48 of 51 jurisdictions, your bank must notify the bar when a trust account is overdrawn. The exceptions are Mississippi, South Dakota, and Texas — and South Dakota substitutes a disciplinary-board audit trigger on a bounced trust check.
Twelve jurisdictions expressly require it (ten monthly; Massachusetts every 60 days; North Carolina quarterly, with monthly bank reconciliations). Everywhere else it is the working standard that makes the required records possible — and the first thing a bar auditor asks for.
Compiled from state bar rules and IOLTA program sources, October 2026. Full rule citations for every cell are in the handbook. Rules change — confirm your jurisdiction's current rule with your state bar.
| State | IOLTA status — program | Retention | Three-way reconciliation | Bank overdraft notice | What stands out |
|---|---|---|---|---|---|
| Alabama | Mandatory — Alabama Law Foundation | 6 years | Not specified in rule | Yes | Annual IOLTA certification (due 31 Oct); Rule 1.15(e) lists the exact journals, ledgers and electronic-transfer records to retain |
| Alaska | Opt-out — Alaska Bar Association (IOLTA program) | 5 years | Not specified in rule | Yes | Trust accounts only at banks that signed an Overdraft Notification Agreement; lawyer signs a waiver of confidentiality allowing the bank to report |
| Arizona | Mandatory — Arizona Foundation for Legal Services & Education | 5 years | Yes — monthly | Yes | Rule 43 also governs legal paraprofessionals; no overdraft protection permitted on a trust account |
| Arkansas | Mandatory — Arkansas Access to Justice Foundation | 5 years | Not specified in rule | Yes | Separate rule in 1.15(i): client files must be securely stored 6 years (longer than the 5-year trust-record period) |
| California | Mandatory — Legal Services Trust Fund Program, State Bar of California | 5 years | Yes — monthly | Yes | CTAPP (Client Trust Account Protection Program): annual trust-account registration, annual self-assessment and certification with the State Bar, and CPA compliance reviews of selected lawyers (Rules of the State Bar, Title 2, Div. 1.5, eff. 2025) |
| Colorado | Mandatory — Colorado Lawyer Trust Account Foundation (COLTAF) | 7 years | Not specified in rule | Yes | Trust-account rules are split into Rules 1.15A–1.15J; accounts only at Regulation-Counsel-approved institutions |
| Connecticut | Mandatory — Connecticut Bar Foundation | 7 years | Not specified in rule | Yes | Statewide Grievance Committee conducts random audits of lawyer trust accounts |
| Delaware | Mandatory — Delaware Bar Foundation | 5 years | Not specified in rule | Yes | Annual Certificate of Compliance filed with the Lawyers' Fund for Client Protection; trust accounts only at approved institutions with a Delaware presence |
| District of Columbia | Mandatory — DC Bar Foundation | 5 years | Not specified in rule | Yes | Account title must include the lawyer/firm name plus "DC IOLTA Account" or "IOLTA Account"; account must be registered on the DC Bar Foundation's IOLTA registration form; approved-depository system |
| Florida | Mandatory — FFLA (Funding Florida Legal Aid, formerly The Florida Bar Foundation); program is called IOTA | 6 years | Yes — monthly | Yes | Annual trust accounting certificate filed with the Bar 1 June–15 August; multi-lawyer firms must keep a written trust account plan naming the lawyers responsible for reconciliations and trust checks; overdraft protection on trust accounts is prohibited |
| Georgia | Mandatory — Georgia Bar Foundation | 6 years | Not specified in rule | Yes | Trust account must be designated "Attorney Trust Account," "Attorney Escrow Account" or "Attorney Fiduciary Account," and held only at a State-Bar-approved institution that agrees to overdraft reporting |
| Hawaii | Mandatory — Hawaii Justice Foundation | 6 years | Yes — monthly | Yes | Checkbook registers / canceled checks must bear the legend "client trust account"; Disciplinary Board runs a Client Trust Account School |
| Idaho | Mandatory — Idaho Law Foundation | 5 years | Not specified in rule | Yes | On an overdraft notice Bar Counsel demands an explanation plus 6 months of statements on all trust accounts; lawyer has 30 days to respond |
| Illinois | Mandatory — Lawyers Trust Fund of Illinois | 7 years | Not specified in rule | Yes | Lawyers report IOLTA/trust-account status to the ARDC as part of annual attorney registration; overdraft notice automatically opens an ARDC investigation |
| Indiana | Mandatory — Indiana Bar Foundation | 5 years | Not specified in rule | Yes | Overdraft notices are processed centrally by the Disciplinary Commission under Rule 23 §30, including a required lawyer explanation |
| Iowa | Mandatory — Iowa Lawyer Trust Account Commission | 6 years | Yes — monthly | Yes | Unannounced periodic audits of every trust account roughly every 3–4 years by the Client Security Commission; PayPal/Venmo-type platforms and cryptocurrency may not be used with the trust account; trust-account changes must be reported within 30 days |
| Kansas | Opt-out — Kansas Bar Foundation | 5 years | Not specified in rule | Yes | One of only four opt-out states — a lawyer who opts out must still keep client funds in a separate non-IOLTA trust account |
| Kentucky | Mandatory — Kentucky IOLTA Fund (Kentucky Bar Association) | 5 years | Not specified in rule | Yes | IOLTA compliance is certified on the annual bar-dues statement administered by the Kentucky IOLTA Fund board |
| Louisiana | Mandatory — Louisiana Bar Foundation | 5 years | Not specified in rule | Yes | Every lawyer must file an annual Trust Account Disclosure & Overdraft Notification Authorization with the Office of Disciplinary Counsel — including lawyers who handle no client funds, who must certify that fact |
| Maine | Mandatory — Maine Justice Foundation | 5 years | Not specified in rule | Yes | IOLTA participation is certified through the Board of Overseers' annual registration process |
| Maryland | Mandatory — Maryland Legal Services Corporation (statutory program) | 5 years | Not specified in rule | Yes | Bookkeeping is governed by a separate chapter (Title 19, Ch. 400) from Rule 1.15, with a prescribed chronological deposit/disbursement record format; cash disbursements from trust are prohibited (a Maryland lawyer was disbarred in part for cash disbursements and checks to third parties) |
| Massachusetts | Mandatory — Massachusetts IOLTA Committee | 6 years | Yes — every 60 days | Yes | The rule expressly provides that no individual client balance may be negative at any time and treats bank fees/charges as a separate client record in the reconciliation |
| Michigan | Mandatory — Michigan State Bar Foundation | 5 years | Not specified in rule | Yes | Accounts only at State-Bar-approved institutions; on an overdraft inquiry the lawyer must answer the Grievance Administrator in writing within 21 days |
| Minnesota | Mandatory — Minnesota IOLTA Program (administration reported moved to the State Board of Civil Legal Aid, 1 July 2025) | 6 years | Yes — monthly | Yes | OLPR, on an overdraft notice, requires the trust books for the 3 months including and preceding the overdraft; lawyers with minor recordkeeping faults are routinely worked with without a disciplinary file |
| Mississippi | Mandatory — Mississippi Bar Foundation | 7 years | Not specified in rule | No | One of only three states with no bank overdraft-notification rule; combined with the joint-longest (7-year) retention period |
| Missouri | Mandatory — Missouri Lawyer Trust Account Foundation | 5 years | Not specified in rule | Yes | Annual certification of trust-account compliance (or exemption) with the Bar; narrow exception allowing small flat fees under $2,000 outside trust |
| Montana | Mandatory — Montana Justice Foundation | 5 years | Not specified in rule | Yes | Trust funds must be kept under Rule 1.18 (IOLTA) read together with Rule 1.15; unclaimed IOLTA funds are remitted to the Foundation on a dedicated form |
| Nebraska | Opt-out — Nebraska Lawyers Trust Account Foundation | 5 years | Guidance only | Yes | Annual IOLTA certification to the Supreme Court; Counsel for Discipline may audit a trust account at any time |
| Nevada | Mandatory — Nevada Bar Foundation | 5 years | Not specified in rule | Yes | Records must "expressly reflect the date, amount, source, and explanation" for every receipt and disbursement, and must be produced to the State Bar on request |
| New Hampshire | Mandatory — New Hampshire Bar Foundation | 6 years | Not specified in rule | Yes | Annual trust-account compliance certificate under Rule 50; New Hampshire is one of the long-standing random-audit jurisdictions |
| New Jersey | Mandatory — IOLTA Fund of the Bar of New Jersey | 7 years | Yes — monthly | Yes | Random Audit Program (Office of Attorney Ethics) — firms are audited without any suspicion of wrongdoing; Rule 1:21-6 also prohibits ATM cards and overdraft protection on trust accounts, requires accounts in New Jersey titled "Attorney Trust Account," and prescribes records for the business account too |
| New Mexico | Mandatory — State Bar of New Mexico IOLTA Program | 5 years | Yes — monthly | Yes | Every firm must keep a written trust account plan naming the attorneys responsible for the accounts, for the monthly reconciliations, and for answering Disciplinary Board questions, and must report every trust account (institution + account number) on an annual certificate of compliance |
| New York | Mandatory — IOLA Fund of the State of New York (program is called IOLA) | 7 years | Not specified in rule | Yes | Only a lawyer may be an authorized signatory on a trust account; no overdraft protection and no linking a trust/escrow account to a personal account; some Appellate Division departments conduct random audits |
| North Carolina | Mandatory — North Carolina IOLTA (State Bar) | 6 years | Yes — quarterly* | Yes | Random audit / Trust Account Compliance program operating since 1985; a written accounting to the client is required at least annually if funds are held more than one year |
| North Dakota | Mandatory — North Dakota Bar Foundation | 6 years | Not specified in rule | Yes | Lawyer must certify compliance with Rule 1.15 every year on licence renewal, in the form prescribed by the Clerk of the Supreme Court (Rule 1.15(i)) |
| Ohio | Mandatory — Ohio Access to Justice Foundation | 7 years | Not specified in rule | Yes | Retention clock runs from termination or disbursement (whichever is first) — earlier than most states; the fee agreement for each client must also be kept for the full 7 years |
| Oklahoma | Mandatory — Oklahoma Bar Foundation | 5 years | Not specified in rule | Yes | Model-rule text; the Bar's retention guidance warns the 5-year trust period is a floor and recommends 7 years for closed files generally |
| Oregon | Mandatory — Oregon Law Foundation | 5 years | Yes — monthly | Yes | The lawyer must also promptly notify Disciplinary Counsel in writing of an overdraft (bank name, account number, date) — self-reporting on top of bank reporting; every active lawyer must certify IOLTA status annually (ORS 9.675), including lawyers who hold no client funds |
| Pennsylvania | Mandatory — Pennsylvania IOLTA Board | 5 years | Not specified in rule | Yes | Overdraft notification sits in the Disciplinary Enforcement rules, not Rule 1.15; IOLTA status is reported on the annual attorney registration |
| Rhode Island | Mandatory — Rhode Island Bar Foundation | 7 years | Not specified in rule | Yes | Joint-longest retention period (7 years) in a model-rule state — bookkeepers used to the 5-year norm must extend Rhode Island files |
| South Carolina | Mandatory — South Carolina Bar Foundation | 6 years | Not specified in rule | Yes | Trust accounting has its own rule — Rule 417 SCACR (financial recordkeeping) in addition to Rule 1.15, including a prohibition on disbursing against uncollected funds |
| South Dakota | Mandatory (converted 2017) — South Dakota Bar Foundation | 6 years | Yes — monthly | No | The whole regime is in a statute (SDCL 16-18-20.2), not a court rule; annual trust accounting certificate filed with the State Bar between 1 December and 31 January; an annual detailed listing of each client's unexpended balance is also required |
| Tennessee | Mandatory — Tennessee Bar Foundation | 5 years | Guidance only | Yes | Overdraft reports go to the Board of Professional Responsibility, which runs trust-account workshops; IOLTA enrollment is through the Tennessee Bar Foundation's eligible-institution list |
| Texas | Mandatory — Texas Access to Justice Foundation (TAJF) | 5 years | Guidance only | No | Notify TAJF in writing/electronically within 30 days of opening or closing an IOLTA account, and certify IOLTA status annually; non-compliance can lead to administrative suspension |
| Utah | Mandatory — Utah Bar Foundation | 5 years | Not specified in rule | Yes | Model-rule safekeeping text; IOLTA interest is administered by the Utah Bar Foundation while discipline sits with the Office of Professional Conduct |
| Vermont | Mandatory — Vermont Bar Foundation | 6 years | Not specified in rule | Yes | Vermont is one of the ABA-listed random-audit jurisdictions; 6-year (not 5-year) retention is the trap for multi-state firms |
| Virginia | Mandatory (converted 2022 — the most recent conversion in the country) — Legal Services Corporation of Virginia | 5 years | Not specified in rule | Yes | Because conversion was in 2022, older Virginia guidance describing an opt-out program is stale and should not be relied on; overdraft reporting runs through approved depositories under Paragraph 20 |
| Washington | Mandatory — Legal Foundation of Washington | 7 years | Not specified in rule | Yes | Safekeeping is split across RPC 1.15A (general duties), 1.15B (required records) and 1.15C; the 7-year duty survives dissolution or sale of the practice — arrangements for the records must be made on exit (1.15B(b)); random trust-account examinations are authorised under ELC Title 15 |
| West Virginia | Mandatory — West Virginia State Bar (IOLTA program) | 5 years | Not specified in rule | Yes | IOLTA is administered by the State Bar itself rather than a separate foundation — interest and compliance run through the Bar |
| Wisconsin | Mandatory — Wisconsin Trust Account Foundation (WisTAF) | 6 years | Not specified in rule | Yes | Print rule: for an IOLTA account the transaction register, subsidiary ledger and reconciliation report must be printed every 30 days and the printed copy kept 6 years (SCR 20:1.15(f)(4)b); annual trust-account certification, with an overdraft-notification agreement filed for each account |
| Wyoming | Opt-out — Equal Justice Wyoming Foundation | 5 years | Not specified in rule | Yes | Lawyers maintaining a trust account are deemed to have consented to overdraft reporting to the Office of Bar Counsel — the consent language also appears on the annual licence-fee statement; Wyoming's 2016 adoption made it one of the last states to adopt overdraft notification |
*North Carolina requires a quarterly three-way reconciliation plus monthly bank reconciliations. Trust-account compliance responsibility stays with the firm and its attorneys — we keep the client ledgers and reconciliations that compliance requires, to your jurisdiction's rules.
The matrix is one reference table from Accounting Books for Attorneys — our 105-page handbook: trust accounting fundamentals, QuickBooks Online and Xero setup step by step, the monthly checklist and the three-way reconciliation, worked examples, and a full section on every state's rules. Download it free, and if your firm's books need hands, our Nationwide Attorney Specialist, Marufa Akter, runs this practice — monthly bookkeeping from $275, cleanup from $495.
Rafael Rodriguez, Jr., MBA is a tax preparer, not a CPA — the CPA is a higher, state-licensed credential. Services requiring a CPA are performed by our licensed CPA on staff.
