Myth vs Fact: Does Every Electronic Trust Transfer Require Two People? Understanding Form 9A in Ontario

The myth: Two people must always enter and authorize an electronic trust transfer

Electronic trust transfers are an important part of modern legal practice. But when it comes to trust accounting, convenience must never come at the expense of proper authorization and documentation.

One common misconception is that every electronic trust transfer must always involve two different people: one to enter the transfer details and another to authorize the transaction.

The fact? Ontario's rules provide a conditional exception.

Under the Law Society of Ontario's By-Law 9, a single licensee may complete an electronic trust transfer when the applicable conditions are met, including the use of unique user credentials and a system that generates immediate confirmation when the transfer is completed. Firms must verify that their particular process satisfies the current requirements.

What is Form 9A?

Form 9A is the electronic trust transfer requisition used under Ontario's trust-accounting rules. It documents the authorization and details associated with an electronic withdrawal of trust money.

The purpose is not simply to create another piece of paperwork. Proper documentation helps establish a clear record of the transaction, including the client matter, amount, destination and authorization.

The Law Society's guidance also recognizes that the required information may be recorded in another format where permitted. Firms should consult the current By-Law 9 and applicable Law Society guidance before changing their procedures.

Why does this distinction matter?

Misunderstanding the rule can create two different problems.

First, a firm may introduce unnecessary administrative steps because it believes that a second person is mandatory in every circumstance.

Second, a firm may assume that a single-person workflow is acceptable without confirming whether the required safeguards are actually in place.

Neither assumption is a sound substitute for understanding the applicable requirements.

Before adopting a workflow, consider these questions:

• Does the electronic transfer system use unique user credentials?
• Does it generate immediate confirmation when the transfer is completed?
• Are the applicable requisition and authorization requirements being followed?
• Are the transaction records and supporting documentation being retained appropriately?
• Has the firm's procedure been checked against the current By-Law 9 requirements?

These checks help firms distinguish between a permitted workflow and an undocumented shortcut.

How can legal accounting software help?

A well-organized legal accounting workflow can make it easier to trace financial activity to the appropriate client matter and maintain accessible accounting records.

With uLaw Practice, legal professionals can use integrated legal practice management and accounting workflows to support more organized financial administration. Keeping matter information and accounting activity connected can help reduce scattered records and make routine financial reviews more manageable.

Software is a tool, not a substitute for professional responsibility. Firms should verify the capabilities of their chosen system and ensure that their own authorization, confirmation and record-retention procedures meet the applicable rules.

The takeaway

Myth busted: Two people are not necessarily required for every electronic trust transfer in Ontario.

A single licensee may complete a transfer when the applicable conditions are satisfied. The important point is to understand the rule, maintain the required documentation and ensure that the process is appropriate for the firm's circumstances.

Better systems can support better recordkeeping—but compliance begins with knowing the requirements.

Explore how uLaw Practice can help your firm organize its legal accounting workflows.

Disclaimer: This article is for general educational purposes only and is not legal or accounting advice. It addresses Ontario requirements and should not be interpreted as applying uniformly across Canada. Consult the current Law Society of Ontario By-Law 9 and applicable guidance before relying on this information.