People are more connected today than ever, a phenomenon accomplished through advances in telecommunication technology, the increased availability of powerful personal devices, and a greater reliance on social media. Unfortunately, the rise of fraud through the inappropriate use of telecommunications and social media poses a significant threat to the well-being of individuals and the financial institutions that serve them. Banks and credit unions will always play a fundamental role in protecting our customers and combating scams, but given the sophistication in the methods of communications and the prevalence of the use of devices in conducting financial transactions, we can no longer do this alone.

To address this challenging problem, we need a holistic solution; one that includes not only financial institutions but social media platforms, telecommunication companies, and government. The California Credit Union League and the California Bankers Association are united on the importance of advancing meaningful change and are sharply focused on preventing increased fraud and scams through a multi-pronged approach. 

Fighting fraud holistically through shared responsibility 

Bank customers and credit union members navigate an increasingly complex digital landscape. We can no longer rely solely on financial institutions to detect and prevent fraud. A comprehensive approach calls for shared responsibility, as scammers have become more sophisticated, using tactics that attempt to thwart the most vigilant financial institutions. 

In fact, on December 11, 2024, Acting Comptroller of the Currency, Michal Hsu, underscored the need for collective action from all stakeholders, including banks, telecommunication companies, social media platforms, and regulatory bodies, to combat fraud. We agree with Acting Comptroller Hsu and we are eager to partner with all stakeholders to address this important issue.

Banks and credit unions can do more 

To better protect customers, banks and credit unions can provide opportunities for certain accountholders to identify a trusted contact that the financial institution can outreach to when there is suspected fraud perpetrated against our most vulnerable customers. Allowing banks and credit unions to place a permissive hold on suspicious transactions can also prevent funds from ever leaving the bank. 

Building a collaborative defense

A collaboration between social media platforms and financial institutions would be a leap in the fight against fraud. Imagine if social media platforms worked closely with banks and credit unions to identify potentially fraudulent activity? By opening the lines of communications, platforms could alert financial institutions to suspicious activities that are targeting their users leading to swifter action on unusual transactions.

We believe such a partnership could be mutually beneficial, as one component in helping to protect our members and customers, while also enhancing the overall security of social media platforms. Sharing information on known fraudulent accounts and implementing enhanced verification features for in-app purchases could create a barrier against fraud and enable a safer online experience.

Taking a stand against fraudulent communications

Telecommunications companies play a pivotal role in combating fraud, as such activity is often initiated through phone calls and messaging services. To help alleviate scams, telecommunications providers could enhance caller authentication through technologies like the Secure Telephone Identity Revisited (STIR) and Signature-based Handling of Asserted Information Using toKENs (SHAKEN). STIR/SHAKEN helps identify and label spoofed calls and digitally validates the handoff of phone calls passing through the complex web of networks, allowing the phone company of the consumer receiving the call to verify that a call is from the number displayed on Caller ID.

Getting too social on social media

Social media sites can foster financial scams. In some cases, fraudulent accounts can be created with minimal oversight. Under federal law, financial institutions are required to comply with Know Your Customer laws to combat fraud and other illicit activities. Implementing a more robust identify verification process for social media platforms at account creation would be meaningful.

By adopting identity verification protocols such as multi-factor authentication, biometric checks, and linking user profiles to verified phone numbers or government-issued IDs, social media platforms can create a more secure environment. Enhanced account verification would make it difficult for scammers to establish fake profiles, thereby protecting their users and the broader community. While some social media platforms already offer account verification processes, we believe a more comprehensive industry standard would provide greater protections. 

Boosting fraud awareness 

Social media companies are in a unique position to educate their users through public awareness campaigns. These campaigns can highlight common fraudulent techniques, such as cryptocurrency fraud, phishing schemes, and romance scams. 

By issuing warning messages about trending fraud attempts—especially against vulnerable populations, sharing safety tips, and providing guides on reporting suspicious activity—social media platforms can empower users to be more vigilant and proactive in protecting themselves.

Public awareness campaigns led by telecommunication providers can complement these efforts. For example, text alerts warning about recent frauds, information on apps, and educational content shared via media outlets can keep users informed and prepared.

At the federal level, lawmakers are advancing legislation to reduce cybersecurity risks through public awareness campaigns. In 2023, Congressman Jay Obernolte (R-CA) introduced the American Cybersecurity Literacy Act (HR 1360). The bipartisan legislation requires the National Telecommunications and Information Administration to establish a cybersecurity literacy campaign to increase knowledge and awareness of cybersecurity risks. This is a step toward more digital security and fraud prevention.

Empowering Adult Protective Services

The Adult Protective Service (APS) office operated at the county level plays a critical role in protecting vulnerable individuals from financial abuse. However, APS needs more resources to combat this problem. Lawmakers should do their part by increasing funding for APS, especially funding contingent on hiring more investigators dedicated to suspected financial abuse cases. With more resources, APS can improve its capacity to prevent and respond to potential crimes targeting vulnerable populations.    

Also, requiring APS to inform mandated reporters of known or suspected financial abuse, like credit unions and banks, about the outcomes of their investigations can help assess the effectiveness of preventative measures deployed by credit unions and banks and assist with adapting strategies based on feedback.

Conclusion

We look forward to collaborating with telecommunications companies, social media platforms and the government to strengthen our collective efforts to fight fraud. Working together, we can achieve meaningful change that protects the well-being and security of our customers. As Acting Comptroller Hsu put it, solving this problem is going to require “each and every stakeholder to step up and do their part to combat fraud.”

AB 909, introduced by Assemblymember Schiavo, seeks to expand protections for elder and dependent adults who fall victim to fraud by creating significant and problematic liability exposure for banks and financial institutions, fundamentally altering long-standing standards of consumer responsibility, due process, and operational feasibility in fraud detection.

Among other things, this measure redefines “fraudulently induced transactions” and limits consumer liability for them to just $50—or the value lost before the bank had reason to suspect fraud—regardless of how the transaction was authorized. Financial institutions would bear the burden of proof to show that the transaction was not fraudulent or that the consumer failed to report it in time. This inversion of liability and investigative burden ignores the fact that many such scams are engineered to appear legitimate and are intentionally designed to evade detection, even by well-trained fraud departments.

The bill also requires banks to investigate and determine within 10 business days whether a consumer is a victim, with potential treble damages, statutory penalties, and attorneys’ fees for noncompliance. The bank has the burden of proof to disprove the allegation of induced fraud. These requirements are operationally unrealistic given the complexity of fraud cases and the need for due diligence. Moreover, the bill extends joint liability to other institutions that may have merely received transferred funds, creating a sweeping net of legal exposure across the financial system.

SB 505, authored by Senator Richardson, introduces new consumer protections in response to the rise of fraud in digital wallets and stored value platforms. The bill requires operators of these platforms to reimburse users for losses resulting from fraudulently induced transfers, where a consumer is tricked into sending money under false pretenses.

The legislation defines these transfers as those initiated due to manipulation, deception, or coercion, even if the consumer technically authorized the transaction. By shifting liability to the platform, SB 505 challenges the commonly accepted principle that holds consumers responsible for authorized payments—even when made under fraudulent influence.

The bill mandates multiple channels for customers to submit reimbursement claims, including via app, website, email, phone, or mail. Operators must investigate claims within 10 business days or provisionally credit the user while extending the investigation up to 45 days. No police report is required to initiate the process. Once a fraud is confirmed, reimbursement must occur within one business day.

While the legislation exempts banks, SB 505 represents a frightening shift—treating fraud losses as a platform responsibility rather than a consumer risk. 

By Chris Shultz, Vice President, Government Relations

A proposal pending in the California legislature would offer voluntary, zero-fee, zero-penalty, federally insured, no cost accounts to all Californians. While California banks generally agree with the public policy goal of providing all Californians access to safe, affordable banking products at insured depository institutions, this 2025 proposal goes far beyond serving the truly unbanked.

Low interest, small target

In 2021, the Legislature created a CalAccount Blue Ribbon Commission under the State Treasurer, with SoFi Bank's Virginia Varela and Legacy Bank's James D. Hicken representing banking interests. The July 2024 report revealed that 5.1 percent of California households are unbanked, with half of those households “not interested” in having a bank account.

Since the Blue Ribbon Commission report, the Federal Deposit Insurance Corporation released an updated study documenting the steady decline of unbanked households in California: from 5.6 percent in 2019 to 5.0 percent in 2021, and further reducing to 4.3 percent by 2023.

The feasibility assessment confirmed low interest in CalAccount: only 10 percent of unbanked households were 'very interested', while approximately 50 percent remained 'not interested' in having a bank account.

Takes customers and deposits out of banks and credit unions

Hidden in the report, enrollment estimates reveal that merely 30 percent of potential CalAccount consumers would be truly unbanked. To achieve sufficient enrollment, the feasibility study would necessitate moving 467,000 to 631,000 households—representing $31-92 million in revenue—away from their current banks and credit unions.

CalAccount would require a 10-year subsidy

The feasibility study identified state general fund costs of $121 to $201 million over ten years, but the potential fraud costs, and whether those costs would be borne by the state or the financial services provider, were not addressed in the feasibility study. The feasibility study also found that it costs credit unions and banks $175 to $400 per year to maintain a bank account while each CalAccount would require an operating subsidy.

California government not more trusted than banks

Advocates assume the state seal would attract new customers, but the unbanked population's trust in banks (56.3 percent) is nearly identical to trust in California government (57 percent). This casts doubt on whether CalAccount would appeal to unbanked individuals. Furthermore, the study did not investigate how many unbanked people might be intentionally avoiding government tax and child support levies.

New mandates on businesses and landlords 

AB 1365 would require employers with more than 10 employees to offer CalAccount direct deposit, contractors with over 25 workers to use CalAccount payments, and all landlords to accept CalAccount rent payments. These extensive mandates would impact nearly every business and property owner in California.

Private-sector alternatives exist

Banks and credit unions are already addressing unbanked populations through the BankOn program. This initiative provides safe, affordable transaction accounts with low fees, no overdraft charges, and robust banking capabilities. With many California financial institutions already participating, promoting BankOn would be a more cost-effective and lower-risk approach than AB 1365.

State and Federal Lawmakers Return to Work: New Faces, Bold Agendas, and the Fight to ‘Trump-Proof’ the State"

California's 2025-2026 legislative session commenced on January 6 with an influx of 37 freshman legislators—24 in the Assembly and 13 in the Senate—comprising nearly one-third of the 120-member body.  This substantial turnover is among the largest in recent history, reflecting the dynamic nature of California's political landscape. This new group of legislators brings a diverse array of experiences, comprised of former local government officials, community activists, and professionals from various industries. A record high 49% of the seats (59 seats) are now filled by female legislators-double the number from seven years ago.  The state Senate has achieved gender parity for the first time, with women occupying 21 of the 40 seats. 

Although many members of the freshman class campaigned on pledges to tackle California’s cost of living, healthcare, education, and family services, the new session began with a focus on partisan debates over social issues. Shortly after the presidential election, Governor Gavin Newsom called a special session to “Trump-proof” California, aiming to safeguard the state against potential federal policies that could undermine its progressive agenda. Newsom’s plan includes the expansion of the state’s authority to set stricter environmental regulations, including emissions standards and renewable energy targets, ensuring that California remains a national leader in combating climate change, and fully funding the California Department of Justice for ensuing legal battles with the Trump administration. Additionally, the governor is prioritizing bolstering reproductive healthcare access and LGBTQ+ protections, doubling down on policies to shield vulnerable populations from regressive federal actions. As legislators look to protect California values, these efforts are being balanced against the need to secure federal funding for L.A. wildfire victims. 

State Legislative Outlook

“Trump Proofing” California could also lead to enhanced consumer protections for Californian’s, particularly if policymakers hold the view that Trump is likely to weaken the Consumer Financial Protection Bureau. As we survey the landscape of potential legislative action relative to banking, there are number of legislative proposals that may surface in the 2025-206 legislative session. 

• State-Level CRA

Lawmakers may look to revive past efforts to adopt state-level Community Reinvestment Act (CRA) requirements to ensure financial institutions meet the credit needs of underserved communities. These efforts aim to fill gaps left by federal regulations, which do not require CRA compliance for Credit Unions. While CBA supports efforts to extend CRA obligations to credit unions, we remain concerned about legislative proposals that impose new requirements on state-chartered banks, which has the potential to create duplicative reporting requirements.

• Elder Financial Abuse

The legislature believes that it still has work to do to strengthen protections against elder financial abuse, especially following the Governor's veto of SB 278 (Dodd) last year. Legislators argue that banks should play a more active role in combating elder financial abuse by implementing stronger safeguards. They emphasize the need for financial institutions to better train staff to detect and prevent fraudulent activities targeting seniors. CBA is sponsoring AB 83 (Pacheco) to provide immunity protection for financial institutions when they elect to hold or deny suspicious transactions. The measure also permits financial institutions to share transaction information with a third party designated by a senior accountholder if fraud is suspected. 

• Payments Fraud

Lawmakers are increasingly considering measures to hold banks accountable for preventing payment fraud. These measures aim to reduce fraudulent activity while ensuring banks take a more proactive role in safeguarding their customers’ funds.

• Interchange 

Following the enactment of Illinois’ Interchange Fee Prohibition Act earlier this year, states are beginning to explore interchange fee legislation to address concerns about the financial burden these fees place on small businesses and consumers. Proposed measures aim to cap or regulate fees that merchants pay to banks and credit card companies for processing transactions justified by the specious assertion that reduce costs for businesses translates to lower prices for consumers. 

• Public Banking

With the completion of the Cal Accounts feasibility study earlier this year, and the ensuing endorsement of the California State Treasurer, introduction of implementing legislation to create the program seems likely. Proponents of AB 857 (Chiu) are attempting to advance legislation to weaken the protections negotiated by CBA in 2019. AB 857 allows local governments to apply for a public bank charter with the Department of Financial Protection and Innovation, provided specified conditions are met. The advocates are seeking to weaken the collateral and capital requirements imposed by the enacted measure, and to remove the sunset date which allows the statute to expire 2029. Public banking groups are also advocating for elimination of the requirement that public banks obtain FDIC insurance before applying for a state charter. 

• Privacy and AI

Privacy remains a perennial issue for the state legislature and policymakers will continue to advance proposals to regulate artificial intelligence (AI) to ensure its development and use align with ethical and safety standards. Lawmakers will once again introduce measures requiring transparency in AI algorithms, mandating impact assessments for high-risk applications, and establishing accountability for misuse or harm caused by AI systems. 

• Homeowners Insurance

CBA will continue to participate in discussions on homeownership availability. Arguably the most pressing issue before the legislature this year, many homeowners are being forced to seek coverage through the state's FAIR Plan, an expensive last-resort insurance option. This situation has sparked concerns about affordability, housing market stability, and the need for regulatory reform to ensure that homeowners can access reliable and affordable insurance coverage in the future.

 The primary drivers of this crisis are escalating wildfire risks, with the most recent fires in Los Angeles raising concerns about uninsured or underinsured homeowners.

• Mortgage Relief

California banks are providing vital mortgage relief for homeowners in areas impacted by the wildfires, but California lawmakers are already pursuing additional mortgage relief measures to help homeowners affected by wildfires and the financial strain caused by property losses and rising insurance costs.

Federal Legislative Outlook

The re-election of President Donald Trump is likely to bring significant changes to banking regulations, with discussions underway about consolidating or even eliminating key regulatory agencies. Generally, it is believed that the regulatory climate will be more favorable to banks, which might include streamlining merger approval processes and lowering compliance burdens. Additionally, the administration is expected to be bullish on cryptocurrency and artificial intelligence, with efforts underway to ease regulatory scrutiny of technology. 

Senator Tim Scott of South Carolina has been selected to chair of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, becoming the first African American senator to chair a full Senate committee. The Senator has said his focus will be on financial inclusivity and access to capital. 

Congressman French Hill (AR) has been appointed as the new Chair of the House Financial Services Committee. Hill has extensive experience in banking and finance and is a strong advocate for community banking.  As Chair, he is poised to play a central role in shaping banking policy and advancing Trump’s agenda. Rep. Maxine Waters (CA) will retain her ranking minority leader status on the committee and is expected for focus on affordable housing. 

In 2023, Governor Newsom signed into law measures SB 253 and SB 261, both of which mandate climate-related disclosures. Both measures impact financial institutions that meet the qualifying factors for reporting entities. Note that one of the qualifying factors is doing business in the state of California (rather than, for example, being headquartered in California). The California state agency overseeing these mandates is the California State Air Resources Board (CARB), which is required to complete subsequent implementing regulations on or before January 1, 2025. Both measures also empower CARB with enforcement authority via administrative penalties.

SB 253 requires reporting entities to disclose on an annual basis its Scope 1, 2, and 3 greenhouse gas emissions. By 2026 entities are mandated to begin reporting scope 1 and scope 2 emissions on the prior fiscal year and obtain limited third-party assurance for these reports. By 2027, entities will begin reporting scope 3 emissions on the prior fiscal year. By 2023, companies will need to obtain reasonable, third-party assurance for their scope 1 and 2 emissions reporting and limited third-party assurance for their scope 3 emissions reporting. The measure does not contain exemptions for any sectors of scope 3 reporting, which indicates that Scope 3 Category 15 Financed Emissions will be required in a financial institution's report.

SB 261 requires reporting entities by January 1, 2026 and biennially thereafter to submit a climate-related financial risk report that is consistent with the recommendations of the Task Force on Climate-Related Financial Disclosure's (TCFD) framework in addition to its steps taken to reduce and adapt to the disclosed climate-related financial risk. Importantly, the measure allows for reporting entities to provide thorough explanations of gaps in reporting, in the event that the entity is unable to fulfill all of the recommended requirements and reports may be consolidated at the parent company level. This measure also states that a covered entity satisfies the reporting requirements if it prepares a publicly accessible, substantially similar report pursuant to another law or regulation.

When he signed SB 253 and SB 261 into law, California’s Governor Newsom instructed the legislature to work on subsequent legislation to address his concerns about cost and feasibility of timelines, for both covered entities as well as the state agency. Since convening the 2024 Legislative Session, neither author has introduced a measure to address such work.

In press statements, the author of SB 253 has vehemently defending the legislation, saying, “It’s both inexpensive and easy for corporations to make these disclosures … large corporations — particularly fossil fuel corporations and large banks — are absolutely terrified that if they have to tell the public how dramatically they’re fueling climate change, they’ll no longer be able to mislead the public and investors.”

Both measures will require a significant allocation from the state budget's general fund to CARB for the purpose of implementation and oversight. California is facing a sizable budget downfall – estimates range from approximately $30-$70 billion. As a result, the governor's draft state budget proposal, presented in January, delayed decisions on all recently enacted legislation; while not exclusive to SB 253 and SB 261, those measures were included in the decisioning delay. At that time, the governor announced that the administration would reexamine these funding allocations during the May Revise, a time when the state budget projections are updated with further data. Recently, the California Department of Finance posted its Budget Change Proposal to fully fund CARB for the implementation of SB 253 and SB 261. California lawmakers must approve a state budget by June 15, which is typically followed by Budget Trailer Bills that implement the language of the state budget.

The general practice of state agencies is to begin promulgation of regulations after the agency has received the funding to do so – CARB has confirmed that this practice will stand. In the event that the agency is not funded to implement the program, the statutory deadlines will still stand and would need to be updated, likely through a Budget Trailer Bill, which would happen sometime over the late weeks of summer in anticipation of the legislature’s final August 31 deadline.

Meanwhile, the U.S. Chamber of Commerce filed suit on both laws, based on a first amendment violation as well as a Dormant Commerce Clause violation. Most recently, the judge assigned to the case recused himself and a new judge was appointed. That case continues to move forward.

In this context it is also worth noting two measures that impact the voluntary carbon offset (VCO) space. Although it garnered less attention and the two aforementioned measures, AB 1305 was also signed into law last year and requires entities to disclose specified information in the event that the entity makes a net-zero or related claim. The measure also requires a number of disclosures associated with VCO transactions. This measure does not require implementing regulations by CARB. The author more recently asserted that he intended for reporting to begin January 1, 2025, and is pursuing a legislative path to codify that intent. Currently the legislature is also considering SB 1036, which adds claims made about VCOs to the False Advertising Law.

CBA continues to monitor these issues closely and will report on substantive updates

By: Jason Lane, SVP, Director of Government Relations

During this past legislative session, CBA advocated on a myriad of legislative measures, and while important proposals related to automated decision making, privacy and elder financial abuse failed to advance, we attempted to negotiate compromises on several measures that will become law next year. In all, legislators introduced 4,821 bills this session and sent 2,252 to Gov. Gavin Newsom. We have highlighted a few measures that may require new compliance obligations.

AB 2067 (Dixon): Financial Institutions: Service of Process

Existing law permits financial institutions to designate a third-party agent as a central location for service of legal process. AB 2067 specifies that if the financial institution designates a third-party agent as a central location, the financial institution is also required to designate another central location. The measure prohibits each central location from being located in the same county as another designated central location. Some institutions may need to submit their second location to the Department of Financial Protection and Innovation.

AB 2837 (Bauer-Kahan): Civil Actions: Enforcement of Money Judgments

This measure places a number of new timelines and specific parameters on bank levies, wage garnishment, and claims of exemption. For example, among other provisions, AB 2837 requires a judgment creditor to take additional steps to verify a judgment debtor’s address and provide notice of enforcement to a judgment debtor, by requiring a court to order the return of exempt property that has been levied upon, and limiting the time period during which an earnings withholding order may be enforced and the frequency with which such an order may be sought.

With a coalition of original lenders, debt collectors and debt buyers, CBA opposed AB 2837 and sought amendments that would remove our opposition by addressing our concerns related to the burden of proof of good cause in backdating of exemptions, allowing legal pleadings to be used to verify a debtor’s address in the instance where they have signed up for a cease and desist list, and eliminate the requirement for a judgment creditor to file with the court. Because the author was unwilling to address our concerns, our coalition remained opposed to the measure, which was signed.

SB 1286 (Min): Rosenthal Fair Debt Collection Practices Act: Covered Debt: Commercial Debts.

This measure proposes to add commercial debts of up to $500,000 that are entered into, renewed, sold or assigned on or after July 1, 2025, to the Rosenthal Fair Debt Collection

CBA advocated that the threshold in should be lowered from $500,000 to $100,000; that issues around floor plan financing should be clearly addressed; and that a collector should be able to file a judicial proceeding in the county in which collateral that secures a commercial debt is located. Because proponents ultimately did not address those concerns, CBA remained opposed to the measure.

SB 399 (Wahab): Employer Communications: Intimidation

SB 399 prohibits an employer from subjecting, or threatening to subject, an employee to discharge, discrimination, retaliation, or any other adverse action because the employee declines to attend an employer-sponsored meeting or affirmatively declines to participate in, receive, or listen to any communications with the employer or its agents or representatives, the purpose of which is to communicate the employer’s opinion about religious or political matters and requires an employee who refuses to attend a meeting as to continue to be paid. The measure imposes a civil penalty of $500 on an employer who violates these provisions.

AB 2424 (Schiavo): Mortgages: Foreclosure  

This measure requires a notice be provided to specified parties that a third party, such as a family member, HUD-certified housing counselor, or attorney, may record a request to receive copies of any notice of default and notice of sale at specified times in the loan and foreclosure process and that receiving a copy of these documents may allow the third party to assist the borrower in avoiding foreclosure.

This measure prohibits a foreclosure sale until the expiration of 45 days if the trustee receives, at least five business days before the scheduled date of sale, a listing agreement for the sale of the property subject to the power of sale. If a scheduled date of sale has been postponed and the trustee receives, at least five business days before the scheduled date of sale, from the mortgagor or trustor a copy of a purchase agreement for the sale of the property, the measure requires the trustee to postpone the scheduled date of sale to a date that is at least 45 days after the date on which the purchase agreement was received by the trustee.

This measure requires the mortgagee, beneficiary, or authorized agent to provide to the trustee the fair market value of the property at least 10 days prior to the initially scheduled date of sale and prohibits the trustee from selling the property at the initial trustee’s sale for less than 67 percent of the amount of that fair market value of the property. If the property remains unsold after the initial trustee’s sale, the measure requires the trustee to postpone the sale for at least seven days and authorizes the property to be sold thereafter to the highest bidder.

AB 3100 (Low): Assumption of Mortgage Loans: Dissolution of Marriage  

This measure requires a conventional home mortgage loan originated on or after January 1, 2027, and secured by owner-occupied residential real property containing four or fewer dwelling units with multiple borrowers, to include provisions to allow for any of the existing borrowers to purchase the property interest of another borrower on the loan by assuming the seller’s portion of the mortgage under specified circumstances if the assuming borrower qualifies for the underlying loan, as determined by the lender.

AB 3279 (Committee on Judiciary): Client Trust Accounts (CTA)  

AB 3279 requires that on or after March 1, 2026, and annually on or before March 1 thereafter, a bank must electronically provide via secure file transport protocol or another format mutually acceptable to the financial institution and the State Bar, information for every client trust account actually known to the financial institution associated with an attorney’s State Bar license number.

This obligation to provide information is only for those CTAs associated with an attorney's State Bar license number.

In order to effectuate this new requirement, On or before January 1, 2026, the State Bar must create a standard form for use by an attorney licensed to practice in California wherein the attorney must submit the attorney’s license number and the name and account number of all applicable associated CTAs to the financial institution.

On or before March 1, 2026, and annually on or before March 1 thereafter, a bank must electronically provide via secure file transport protocol or another format mutually acceptable to the financial institution and the State Bar, the following for every client trust account known to the financial institution associated with an attorney’s State Bar license number:

(1) The name of the bank in which the CTA is held

(2) The name of the attorney or law firm associated with the CTA

(3) The account number of the CTA

(4) The attorney’s State Bar license number associated with the CTA

(5) The CTA balance as of December 31 of the previous year. If December 31 is a holiday, the account balance as of the preceding business day may be reported.

Artificial Intelligence (AI) Issue Brief

Elder Financial Abuse Issue Brief

FinTech Issue Brief

Interchange Issue Brief