As a former State Bar prosecutor, Ashod Mooradian is the State Bar and Legal Ethics Expert defense
attorney that brings unparalleled expertise and insight to your case. With nearly a decade of experience
as a lead prosecutor for the State Bar, Ashod has extensive and broad experience with State Bar and
legal ethics cases, having been involved in virtually every type of disciplinary or administrative
proceeding, including being the lead prosecutor on several administrative suspension cases where the
attorney practiced law while suspended during his time at the State Bar’s Office of Chief Trial Counsel.
Ashod has a deep understanding of the State Bar disciplinary system and how the State Bar investigates
and prosecutes allegations of misconduct such as the unauthorized practice of law. In addition, Ashod’s
extensive experience in handling complex legal ethics and professional responsibility issues make him
the ideal advocate for attorneys facing any ethical dilemma, a State Bar complaint investigation, or a
prosecution in State Bar Court or other regulatory challenges.
When your right to practice law is threatened, Ashod is the attorney you want at your side, walking you
through what may be the worst days of your professional career, all the way to a successful conclusion.
It is Ashod’s strategic approach, informed by his State Bar prosecution-specific experience and his
comprehensive knowledge of how the State Bar pursues attorneys accused of misconduct that makes
him the only defense attorney you will need to make sure that your legal ethics problem or your State
Bar prosecution is handled!
REMEMBER THIS—if you are facing an ethical issue, a State Bar complaint, or any regulatory matter
where your right to practice law is at risk, put your trust in the State Bar and Legal Ethics
Expert—attorney Ashod Mooradian. Ashod will handle your case with the expertise and dedication it
deserves because he knows what you’re facing and feeling, can guide you what you have to pass
through, and will get you where you need to end up.
1. What is CTAPP?
CTAPP stands for the Client Trust Account Protection Program. It is designed to ensure proper
accounting and safeguards for client and third-party funds entrusted to attorneys. The program also
aims to educate, support, and assist attorneys in complying with ethical and accounting requirements
for managing client trust accounts.
What are the main requirements of CTAPP?
CTAPP includes several key requirements:
2. What happens if an attorney fails to comply with CTAPP requirements?
An attorney who fails to comply with CTAPP requirements by the deadline (i.e., 02/01/2024) will be
assessed a noncompliance penalty. If the attorney still does not comply with CTAPP as required will
be enrolled to the status of an inactive licensee of the State Bar. This means that the attorney with the
inactive status in suspended from the practice of law. Further, until the inactive attorney is reinstated
to active status, any unauthorized practice of law can result in State Bar discipline, criminal
prosecution and even civil penalties for violations of the State Bar Act, the Rules of Professional
Conduct, or other applicable laws.
3. How can an attorney avoid suspension under CTAPP?
To avoid suspension, attorneys must timely complete their CTAPP requirements. An attorney has
completed their reporting if:
An attorney can verify compliance status by logging into their “My State Bar Profile” located on the State Bar’s website and reviewing on the landing page (the grey box directly under the attorney’s name and license number.) Any missing information will be identified there.
4. What are the deadlines for CTAPP reporting?
For attorneys reporting for the period January 1, 2023 through December 31, 2023, the deadline to
report CTAPP compliance was February 1, 2024. To avoid suspension and penalties (and possible
license discipline), all California attorneys must timely comply with the CTAPP requirements by or
before this deadline.
5. What should an attorney do if they are suspended for CTAPP noncompliance?
If an attorney is suspended, they should immediately seek counsel from an attorney with expertise in
State Bar CTAPP compliance. All of the attorneys who were suspended at the beginning of July
2024 based on their CTAPP noncompliance had to not only complete their CTAPP annual report but
also to pay a $100 noncompliance fee. That noncompliance fee could be paid for by credit card or
ACH electronic debit (aka electronic check), but what suspended attorneys were not told was that
credit card processing takes longer to clear and will thus delay your reinstatement by as much as a
few days. In sum, there are many decisions to be made and each decision can impact the length of
time it takes to get reinstated. If you can’t fully educate yourself on the CTAPP reinstatement
process your only other choice is to retain expert counsel to guide you through to active status.
6. What is the unauthorized practice of law or UPL?
Practicing law while not eligible is called the unauthorized practice of law or UPL. UPL is not only
considered ethical misconduct, but it also considered by the State Bar to be an act of “moral
turpitude.” Business and Professions Code section 6106 states that the “…commission of any act
involving moral turpitude, dishonesty or corruption, whether the act is committed in the course of his
relations as an attorney or otherwise, and whether the act is a felony or misdemeanor or not,
constitutes a cause for disbarment or suspension.” In other words, UPL is very serious misconduct
“practice of law” In addition, because California does not have a statutory definition of the “practice
of law” it is not always clear whether or not a certain action taken by a suspended attorney will be
UPL. Clear examples would be appearing in a court hearing or other hearing on behalf of a client
and providing legal advice to a client. To find out if the action you took during your CTAPP
suspension was UPL, you need to contact a State Bar and Legal Ethics expert defense attorney.
7. What should an attorney do if after they were suspended for CTAPP noncompliance they
“practiced law”?
If an attorney committed the unauthorized practice of law or UPL while on CTAPP suspension, they
will almost certainly be facing a disciplinary investigation from the State Bar’s Office of Chief Trial
Counsel. What does this mean specifically? First, the target attorney (who is called a “respondent” in
the State Bar discipline system) will receive a letter from a State Bar investigator summarizing the
allegations of ethical misconduct and requesting that the respondent explain their conduct, answer
additional questions and provide copies of various documents relevant to the State Bar’s UPL
investigation. It is critical that the response to this investigation be handled just right. Failure to get
your investigation “closed” at the investigation stage will result in the bringing of public charges of
misconduct against the respondent and the commencement of a State Bar Court case to decide
whether or not to impose discipline.
8. How do I know if my attorney has the right experience and knowledge to represent me in a
State Bar investigation?
Many attorneys claim to have the competence to represent attorneys with matters pending before the
State Bar. Usually, such claims are exaggerated and thus to the detriment of the client facing a state
bar investigation or worse, public discipline that will ruin their reputation and cripple their ability to
earn money as an attorney. The most important qualification for any State Bar defense attorney is
not only comprehensive knowledge of the State Bar discipline system but also extensive experience
with State Bar investigations, prosecutions, trials and appeals. The gold standard when it comes to
experience is the former State Bar prosecutor who worked for the agency for a significant period of
time. Look for that experience and this will go further than anything else to confirm that you have
chosen the right attorney to defend you against the State Bar.
9. How long will there be a reference to my CTAPP administrative suspension on my State Bar
Attorney profile?
Under the applicable California Rules of Court and other State Bar rules, any period of
administrative suspension will remain on the Attorney’s profile for at least 7 years, as long as the
suspension did not last longer than 90 days, among other conditions.
10. How much should an attorney being investigated for UPL expect to pay for a defense attorney
and associated litigation costs?
An attorney who was suspended due to CTAPP noncompliance but “practiced law” by appearing in
court or other hearing or provided legal advice, orally or in writing to a client or other act that would
be considered the unauthorized practice of law (UPL) should expect to pay between $15,000 to
$50,000 for their State Bar defense, depending on the experience and qualifications of the State Bar
defense attorney and the nature and extent of the UPL misconduct (e.g., 1 UPL charge vs. 10 UPL
charges.)