Payment control
Two-Person IOLTA Payment Approval
See how two-person IOLTA payment approval separates preparation from release, records both decisions, and supports a law firm's internal controls.
Quick answer
What is two-person IOLTA payment approval?
It is a maker-checker control: one authorized user prepares an IOLTA payment and a different authorized user reviews and approves it before release. For applicable Disbo customers, this approval separation is live and the preparation and approval events remain linked to the matter.
Why a second set of eyes belongs in the payment path
An IOLTA payment can be operationally simple while still carrying significant consequences. A transposed account number, wrong payee, duplicate amount, or payment attached to the wrong matter can be difficult to unwind after release. Email or verbal sign-off may add review, but it leaves the bank action and the approval evidence in different places.
Disbo places the second review inside the payment workflow. The preparer assembles the payee, amount, funding account, matter, and supporting information. A separately authorized approver sees that context before release. The platform records who prepared and who approved the instruction, with timestamps tied to the matter-linked payment history.
This is an internal-control safeguard, not a substitute for legal judgment. The firm remains responsible for deciding who may prepare and approve payments, confirming entitlement and cleared funds, and applying its jurisdiction's trust-account rules.
Exact workflow
Prepare the instruction
An authorized team member selects the matter and IOLTA account, enters the payee, amount, delivery method, and supporting payment details.
Validate the file
The preparer checks the approved settlement breakdown, recipient information, available matter balance, and any required documents before submission.
Route to a separate approver
Disbo holds the instruction for another authorized user rather than allowing the preparer to release it alone.
Review and authenticate
The approver reviews the payment context and completes two-factor authentication for payment approval. A rejected item returns for correction instead of release.
Release and retain the record
After approval, the payment proceeds on the selected rail and the preparation, approval, status, and payment history remain linked to the matter.
Safeguards in the workflow
Separation of duties
Two-person approval prevents the same user from both preparing and unilaterally releasing the applicable IOLTA payment.
2FA at approval
Two-factor authentication adds an identity check at the consequential approval step.
Matter-linked evidence
Payment and approval history identifies the matter, participants, amount, and timestamps for later review.
Continuous reconciliation
Automatic or continuous three-way reconciliation helps surface differences among the bank balance, trust ledger, and matter balances.
Where this applies
- Law firms that require a partner, owner, controller, or other authorized person to release trust payments.
- Teams that want approval evidence attached to the payment rather than stored in email, chat, or paper.
- Applicable customers using Disbo-supported payment and IOLTA workflows.
Limitations to plan for
- Two-person approval cannot determine whether a payee is legally entitled to funds or whether supporting documents are sufficient.
- The firm must configure authorized users, protect credentials, review access regularly, and maintain its own written controls.
- Bank, integration, payment-rail, and account availability can affect the final release process.
Frequently asked questions
Is two-person IOLTA approval live in Disbo?
Yes. Two-person approval is live for applicable customers and separates payment preparation from approval before release.
Can the preparer approve the same payment?
The control is designed so the applicable payment is reviewed by a different authorized user, preserving separation of duties.
Does two-person approval guarantee IOLTA compliance?
No. It supports compliance and stronger internal controls, but it does not guarantee compliance or replace the firm's legal and accounting responsibilities.
See the controlled workflow in Disbo.
Review applicability, integrations, controls, and record exports with the Disbo team.
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