Washington State's Random Trust Account Examinations: What RPC 1.15A Actually Requires
Updated: Sep 9
By Tammy Hoang, Certified QuickBooks ProAdvisor
The Washington State Bar Association has explicit authority under its Enforcement of Lawyer Conduct rules to examine, investigate, and audit the books and records of any lawyer to determine compliance with RPC 1.15A — including examinations of firms selected entirely at random, with no complaint or trigger required. Washington was among the states, alongside New Jersey, that helped establish the model other states later adopted.
This article explains how Washington's random examination authority works, what RPC 1.15A actually requires, and what a firm's trust accounting needs to look like to hold up under review.
Random Examination, Audit, and Investigation: Three Different Tiers
Washington's oversight structure under ELC Title 15 operates in tiers. A random examination looks only at the lawyer's books and records — nothing else. If the examination raises concerns, it can escalate into a full audit, and an audit can in turn support an investigation if the findings warrant it. Each tier carries broader authority than the one before it, but every tier starts from the same place: the trust account records themselves.
Selection for a random examination requires no complaint, no overdraft, and no prior disciplinary history. The Board simply authorizes examinations of books and records selected at random, the same structural approach New Jersey and North Carolina have used for decades.
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What RPC 1.15A Actually Requires
RPC 1.15A governs safekeeping of client property in Washington, requiring client funds to be held in a trust account separate from the lawyer's own funds, with complete records maintained for every trust transaction. As in every jurisdiction with serious trust account enforcement, the requirement is not simply that the pooled account balances — it is that each individual client's portion of that pooled balance can be verified independently.
A firm that only reconciles the trust account against its bank statement, without separately confirming that individual client ledgers sum to the same total, has not actually demonstrated compliance with RPC 1.15A — the same gap that produces findings in every state that examines trust accounts closely.
Overdraft Notification as the Early Warning System
Washington requires trust account depository banks to report any instrument presented against insufficient trust funds directly to the Bar, independent of the random examination program. This overdraft notification requirement functions the same way it does in New Jersey and Delaware — as an automatic, bank-triggered signal that does not depend on the attorney self-reporting or on a random selection ever occurring.
Between overdraft notification and random examination, Washington attorneys effectively face two separate, independent paths to Bar attention: one triggered by an actual shortfall showing up at the bank, and one triggered by nothing more than the luck of random selection.
What an Examination Actually Reviews
A Washington trust account examination reviews the lawyer's books and records specifically — bank statements, the trust ledger, individual client ledgers, and evidence of monthly reconciliation. Because the examination authority under ELC Title 15 exists to "ascertain and obtain reports on whether the lawyer has been and is complying" with RPC 1.15A, the reviewer is looking for exactly the same documentation trail every serious trust-audit jurisdiction expects: individual ledgers that tie out, a reconciliation performed on a real schedule, and records that were maintained as transactions happened, not reconstructed afterward.
A firm cannot talk its way through a documentation gap. Either the monthly reconciliation exists and is signed and dated, or it does not.
How Irvine Bookkeeping Helps Washington Law Firms
Washington's random examination authority rewards the same discipline every serious trust jurisdiction rewards: monthly three-way reconciliation, individual client ledgers maintained continuously, and records that exist before anyone asks for them.
Irvine Bookkeeping prepares monthly reconciliations and maintains client ledgers built to satisfy RPC 1.15A whenever a Washington firm is selected. QuickBooks certified.
Get Your Washington Trust Records Examination Ready.
Book a 30-minute call with Irvine Bookkeeping.
Call or Text: (949) 482-2790 | irvinebookkeeping.com
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