RPC 1.15A vs. RPC 1.15B: Washington's Two Trust Account Rules Are Not the Same Thing
By Tammy Hoang, Certified QuickBooks ProAdvisor
Washington attorneys often refer to "1.15A compliance" as if it covers the whole trust account obligation. It does not. RPC 1.15A and RPC 1.15B are two separate rules governing two separate things, and a firm can be careful about one while quietly failing the other.
Together, violations of these two rules account for roughly ten percent of all cited ethics rule violations in Washington's most recent discipline data — a meaningful share, and one that reflects exactly this confusion between the two provisions.
This article separates what each rule actually requires, and why treating them as one undifferentiated obligation is where compliance gaps hide.
RPC 1.15A: The Safeguarding Rule
RPC 1.15A governs the fundamental duty to safeguard client property. It requires that client funds be held separate from the lawyer's own, deposited into a properly designated trust account, and never commingled except for the minimal amount needed to cover bank charges. It also addresses which financial institutions qualify — a determination LFW makes — and requires prompt delivery of funds or property to a client or third party once the entitlement is undisputed.
This is the rule most attorneys think of when they hear "trust account compliance." It answers the question: is the money in the right place, held the right way, for the right reasons.
Confusing Safeguarding Rules With Recordkeeping Rules?
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RPC 1.15B: The Recordkeeping Rule
RPC 1.15B is a separate rule addressing a separate question: what records must exist to prove RPC 1.15A was actually followed. This is where individual client ledgers, trust account journals, monthly reconciliation, and document retention requirements live. A firm can technically keep client money in the right account and still violate RPC 1.15B by failing to maintain the paper trail that proves it.
Records required under RPC 1.15B must be preserved for at least seven years, organized well enough that the attorney or a regulator could reconstruct the handling of any client's property at any point during that window. This is a documentation standard, not a safekeeping standard — and it is graded independently.
Where the Split Actually Creates Risk
A firm can pass an RPC 1.15A review — the money was always in the right account, nothing was commingled — and still fail RPC 1.15B if individual client ledgers were never maintained, if reconciliations were performed but never documented, or if records were discarded before the seven-year retention period elapsed. From the outside, both look like "trust account problems." To a WSBA examiner under ELC 15.1, they are two distinct findings against two distinct rules.
This is precisely why Washington's discipline data groups these two rules together when reporting violation statistics — in practice, firms rarely fail one without some exposure on the other, because both rules depend on the same underlying monthly discipline to satisfy simultaneously.
Satisfying Both Rules With One System
The practical fix is not treating these as two separate compliance projects. A single monthly discipline — three-way reconciliation, individual client ledgers updated continuously, documentation retained on a real schedule — satisfies RPC 1.15B's recordkeeping standard while simultaneously proving RPC 1.15A's safeguarding standard was followed. The records are the evidence; the safekeeping is the substance.
Firms that build their bookkeeping around this single integrated standard rarely find themselves debating which rule a given gap falls under, because the same monthly process closes both gaps at once.
How Irvine Bookkeeping Helps Washington Law Firms
Compliance with RPC 1.15A and RPC 1.15B is not two separate workstreams — it is one disciplined monthly process that happens to satisfy two rules at once.
Irvine Bookkeeping builds that single process: monthly three-way reconciliation, individual client ledgers, and seven-year record retention, structured to withstand a WSBA examination under either rule. QuickBooks certified.
Satisfy Both Washington Trust Rules at Once.
Talk with Irvine Bookkeeping about integrated RPC 1.15A/1.15B compliance.
Call or Text: (949) 482-2790 | irvinebookkeeping.com
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