Rule 1.15 of the District of Columbia Rules of Professional Conduct, as amended on August 1, 2010, requires that all trust funds be kept in an “approved depository”, and that trust funds that are nominal in amount or expected to be held for a short period of time be held in an approved depository in compliance with the District of Columbia’s Interest on Lawyers Trust Account (“IOLTA”) program. To be an approved depository, D.C. Bar R. XI, § 20 requires a financial institution to file an undertaking with the Board on Professional Responsibility agreeing (i) to report to Bar Counsel overdrafts or other irregularities in trust accounts and to respond to subpoenas from Bar Counsel and (ii) for financial institutions that elect to offer IOLTA trust accounts, to pay interest and charge fees on IOLTA accounts that are comparable to non–IOLTA accounts and to submit the interest and periodic reports to the D.C. Bar Foundation, which administers the IOLTA program.
*** NOTICE: If you maintain funds in a branch of a bank listed below that is located outside the District of Columbia, it is your responsibility to confirm that your branch is in compliance with applicable overdraft reporting and IOLTA requirements. ***
As of September 2012, the following financial institutions have filed the requisite Trust Account Notification Undertaking with the Board on Professional Responsibility and are certified as approved institutions for Trust Accounts and IOLTA Trust Accounts:
- Access National Bank
- Alliance Bank
- Amalgamated Bank
- American Bank
- Bank of America
- Bank of Georgetown
- Branch, Banking & Trust
- The Business Bank
- Capital Bank, N.A.
- Capital One Bank
- Cardinal Bank
- Chain Bridge Bank, N.A.
- Citibank, N.A.
- City First Bank of D.C.
- Colombo Bank
- The Columbia Bank
- Comerica Bank
- Congressional Bank
- Eagle Bank
- Esquire Bank
- First Citizens Bank & Trust Company
- HSBC Bank USA, N.A.
- Industrial Bank of Washington
- Independence Federal Savings Bank
- John Marshall Bank
- Liberty Bank and Trust Company
- Main Street Bank
- M&T Bank
- Monument Bank
- The National Capital Bank of Washington
- Northern Trust Company
- OBA Bank
- PNC Bank
- Premier Bank, Inc.
- Presidential Bank, FSB
- Rappahannock National Bank
- Revere Bank
- Sandy Spring Bank
- SunTrust
- TD Bank
- United Bank
- Virginia Commerce Bank
- Washington First Bank
- Wells Fargo Bank, N.A.
Approved Depositories for Trust Funds (Effective through July 31, 2010)
Prior to August 1, 2010, Rule 1.19 of the District of Columbia Rules of Professional Conduct required that "(a) Funds coming into the possession of a lawyer that are required by these Rules to be segregated from the lawyer’s own funds … shall be deposited in one or more specially designated accounts at a financial institution … (b) The accounts required pursuant to paragraph (a) shall be maintained only in institutions that are listed as ‘D.C. Bar Approved Depositories’ on a list maintained for this purpose by the Board on Professional Responsibility."
The following financial institutions filed the requisite Trust Account Notification Undertaking with the Board on Professional Responsibility and were certified as approved institutions through July 31, 2010:
- Access National Bank
- Adams National Bank
- Alliance Bank
- American Bank
- Bank of America
- Bank of Georgetown
- Branch, Banking & Trust
- Capital Bank, N.A.
- Cardinal Bank
- Century National Bank
- Chain Bridge Bank, N.A.
- Chase Manhattan Bank
- Chevy Chase Savings Bank, FSB
- Citibank, F.S.B.
- City First Bank of D.C.
- Colombo Bank
- Comerica Bank
- Commerce Bank, N.A.
- Commerce Bank/Pennsylvania, N.A.
- Congressional Bank
- Eagle Bank
- Esquire Bank
- First Bank National Association
- First Citizens Bank & Trust Company
- First Liberty National Bank
- First National Bank of Omaha
- HSBC Bank USA, N.A.
- Industrial Bank of Washington
- Independence Federal Savings Bank
- John Marshall Bank
- Main St. Bank
- M&T Bank
- Monument Bank
- National Capital Bank of Washington
- OBA Bank
- PNC Bank
- Presidential Savings Bank, FSB
- Providence Savings & Loan, F.A.
- Rappahannock National Bank
- SunTrust
- United Bank
- United Central Bank
- U.S. Trust Company, National Association
- Wachovia Bank
- Washington First Bank
