Client Trust Accounts - A Lawyer's Responsibility

Transcription

1 Virgin Islands Trust Account Handbook Published as a public service by the Office of Disciplinary Counsel 1 1 This Handbook serves as a practical guide for making trust account decisions. However, it is nonauthoritative, and should be used in conjunction with Supreme Court Rule 211. All decisions relating to trust accounts remain the ultimate responsibility of the individual lawyer.

2 Quick Reference Guide Acknowledgements... 2 Introduction... 3 Trust Funds... 3 Trust Accounts... 4 Delegating Recordkeeping... 5 Trust Account Recordkeeping... 5 Accountings... 6 Client Ledgers... 7 Duties to Third Parties... 8 Reconciliation... 8 Mistakes... 9 Sample 3-Way Reconciliation Worksheet Trust Account Checklist APPENDIX A Selected Virgin Islands Rules of Professional Conduct Acknowledgements Selected excerpts are based on the Handbook on Client Trust Accounting for California Attorneys reprinted with the permission of The California State Bar. Additional selections are based on or adapted from the North Carolina State Bar Lawyer s Trust Account Handbook with permission. Virgin Islands Trust Account Handbook Page 2

3 Introduction A lawyer in possession of client or third-party property is a fiduciary. As a fiduciary, you must safeguard, segregate, and account for those assets. This obligation applies not only to money, but to all forms of property coming into your possession. The obligation applies not only to client funds, but also the funds of third-parties such as lien-holders, court reporters, or even potentially adverse parties in a business transaction. While delegation of administrative functions is permissible, every lawyer must be familiar with and ensure the proper operation and handling of client trust accounts. Trust Funds Trust funds are other people s money that comes into a lawyer s possession. In other words, trust funds are assets in which a client or third party has an interest. Examples include: Prepaid legal fees Prepaid expenses such as court costs or filing fees Funds held for distribution at a later time, such as child support payments or proceeds from a decedent s Estate Client funds due to third-parties Real estate conveyance funds Settlement proceeds held for disbursement Any amounts held in dispute In contrast, fees that are already earned and that are not in dispute are not trust funds, and should not be deposited into a lawyer s trust account. Earned fees must be promptly removed from the trust account in order to avoid co-mingling trust funds with the lawyer s own money. Earned fees should never be parked in the escrow account. All unearned fees, however they are designated, must be initially deposited into the trust account and then transferred to the operating account as the fees are actually earned. There is no such thing as a nonrefundable deposit, retainer, or prepaid fee in the Virgin Islands: If a fee is collected before the fee has been earned, those fees are trust funds. Virgin Islands Trust Account Handbook Page 3

4 Trust Accounts Trust funds are held in a trust account. A trust account is a special bank account, usually a checking or savings account, used to safeguard trust funds. The trust account must be separate from your other personal and business accounts. The account should be designated as a Client Trust Account (or words of a similar nature) and those words should appear on the checks, deposit slips and bank account statements. The account must be located where the lawyer has an office, unless the client consents to having an individual trust account in another location. The trust account may be a single, general trust account where trust funds for many clients are pooled together. Or, a trust account may be a single account for an individual client. A lawyer may have several trust accounts at any one time. As a fiduciary, a lawyer cannot benefit from the administration of a trust account. Therefore, all interest or other income earned on a client trust account belongs to the client or person whose money generated the income. These earned funds, usually interest payments, must be accounted for, and any such income must be promptly reported to the client in accordance with Rule (d). If a pooled account earns interest, then a regular subaccounting must be completed to determine the amount of interest earned by each client and to ensure the proper payment is made to each client. Because this sort of subaccounting can be very cumbersome, most lawyers choose to use non-interest bearing accounts for pooled trust accounts. IOLTA is an acronym that stands for Interest on Lawyer Trust Accounts. The Virgin Islands Supreme Court has not adopted a rule establishing an IOLTA program, or permitting client funds (including interest earnings), to be removed from a lawyer s trust account. In jurisdictions with an IOLTA program, the interest earned in pooled accounts is periodically swept out of the lawyer s trust account, and into the account of the IOLTA organization. The organization, in turn, uses these funds to support approved public interest entities. Because the IOLTA organization is the recipient of any interest earned, its taxpayer identification number is associated with the account, and no subaccounting to the individual clients is required. It is important to note that if significant funds are held for a single client, or if smaller amounts are held for a long time, the use of a pooled trust account is not appropriate. In those cases, the lawyer should deposit trust funds into a separate (i.e. not pooled) interest-bearing account or invest those funds for the benefit of the individual client. The lawyer should use good judgment and consult with the client or third-party in determining how to best safeguard and invest these funds. The lawyer should also be mindful of any applicable income tax reporting requirements and ensure that the proper taxpayer identification number is associated with the account. Virgin Islands Trust Account Handbook Page 4

5 Delegating Recordkeeping The responsibility for compliance with trust accounting rules lies solely with the attorney. This duty cannot be delegated away. However, an attorney may have other persons make the actual entries in the trust account records and perform the monthly reconciliations. The attorney should take care in selecting a bookkeeper, and must ensure that the books are maintained in accordance with generally accepted accounting principles. ABA Model Rules of Professional Conduct 1.15, cmt. 1. All administrative work on trust accounts must be closely reviewed and supervised by the attorney. Lawyers may be professionally responsible for violations that result from failure to have in effect measures giving reasonable assurance that the rules will be followed. Trust Account Recordkeeping Virgin Islands Supreme Court Rule requires the attorney to maintain and preserve complete records of trust account funds and other property held in trust. Generally speaking, either a manual or computerized system can satisfy the recordkeeping requirements if it can generate a list of all activity within the trust account, chronological journals for trust account receipts and disbursements, and a separate ledger for each client or third party that placed funds with the lawyer. Supreme Court Rule clarifies that complete records include: (1) receipt and disbursement journals containing a record of deposits to and withdrawals from client trust accounts, specifically identifying the date, source, and description of each item deposited, as well as the date, payee and purpose of each disbursement; (2) ledger records for all client trust accounts showing, for each separate trust client or beneficiary, the source of all funds deposited, the names of all persons for whom the funds are or were held, the amount of such funds, the descriptions and amounts of charges or withdrawals, and the names of all persons or entities to whom such funds were disbursed; (3) copies of retainer and compensation agreements with clients, as required by Rule ; (4) copies of accountings to clients or third persons showing the disbursement of funds to them or on their behalf; Virgin Islands Trust Account Handbook Page 5

6 (5) copies of bills for legal fees and expenses rendered to clients; (6) copies of records showing disbursements on behalf of clients; (7) the physical or electronic equivalents of all checkbook registers, bank statements, records of deposit, pre-numbered canceled checks, and substitute checks provided by a financial institution; (8) records of all electronic transfers from client trust accounts, including the name of the person authorizing transfer, the date of transfer, the name of the recipient and confirmation from the financial institution of the trust account number from which money was withdrawn and the date and the time the transfer was completed; (9) copies of monthly trial balances and quarterly reconciliations of the client trust accounts maintained by the lawyer; and (10) copies of those portions of client files that are reasonably related to client trust account transactions. According to Rule (a), trust account records must be maintained for five years after termination of the representation. While not explicit in the Rule, records should also be maintained for five years after the last disbursement of funds is made, if this date is later. If computerized accounting systems are used, monthly reconciliation reports, trial balances and client ledgers should be printed and retained. The records must be stored as a snapshot of the trust account at a given time, so that the electronic file cannot change. It is also prudent to back up electronic records at frequent intervals. Accountings Rule requires prompt notification to clients and third parties upon the receipt of funds or other property. It is also advisable to periodically notify each person whose funds are held in trust of the status of those funds and describing any transactions made on his or her behalf. If there is an objection to a disbursement, such as the amount of earned fees, those funds must remain in the trust account pending resolution of the dispute. Generally, clients should be provided complete accountings showing all funds received, deposited, transferred, applied and expended at the close of representations. In contingency fee cases, Rule requires attorneys to provide written statements showing the outcome of the Virgin Islands Trust Account Handbook Page 6

7 matter and, if there is a recovery, showing the remittance to the client and the method of its determination. Client Ledgers The property of each client is distinct, and is not fungible. Client Jones money has nothing to do with Client Smith s money. Even when kept in a single pooled trust account, each client's funds are completely separate from those of all the other clients. In other words, a lawyer is never allowed to use one client's money to pay another client's obligations. Similarly, the lawyer s funds cannot be co-mingled with trust funds and trust funds cannot be used to directly pay the lawyer s personal obligations. The way to distinguish one client's money from another client's money is to keep a ledger of each individual client's funds. This ledger is a listing of the deposits and debits made on the client s behalf. Every time you make a deposit, write the amount of the deposit in the client ledger and add it to the previous balance. Every time you make a payment on behalf of the client, write the amount in the client ledger and subtract it from the previous balance. The result is the running balance for that particular client. The balance represents how much money the client has in trust. If you are holding money in your general trust account for 10 clients, you have to maintain 10 separate client ledgers. If you are only holding $10.00 for a client, you can't write a check for $20.00 on behalf of that client without using some other client's money. This may constitute conversion of client funds, and support a finding of professional misconduct. In other words, you should know exactly how much money you are holding for each of your individual clients, and you should actually have those funds in the trust account no more, no less. Assume you have three clients with the following available trust account balances: Bruce $5, Christine $4, Devon $ In this scenario, you have $9, in your pooled trust account. But, if you write a check for Devon for $700.00, then you have misappropriated $ from Bruce and/or Christine. For this reason, it is also impermissible to spend funds before a deposit has completely cleared the bank. You cannot use one client s money to cover the deposit while the funds clear the bank. Virgin Islands Trust Account Handbook Page 7

8 Many lawyers have small, inactive balances in their trust accounts. Sometimes these balances are the result of a mathematical error, and sometimes a check never cleared or wasn't cashed. Whatever the reason, as long as the money is in your trust account, you are responsible for it. The longer these funds stay in the bank, the harder it is to account for them. Therefore, you should take care of those balances as soon as possible, including, if necessary, following up with payees to find out why a check hasn't cleared. In simplest terms, a lawyer can never distribute more funds than are available on the individual client ledger, nor should there be any money left on the client ledger at the end of the representation. Duties to Third Parties In some circumstances, you have the same duties to third parties as you have to your clients for money you've received and paid out in the context of an attorney-client relationship. An attorney who receives money on behalf of a party who is not the attorney's client becomes a fiduciary to the party with respect to those funds. Where an attorney assumes the responsibility to disburse funds as agreed by the parties in an action, the attorney owes an obligation to the designated recipient to ensure compliance with the terms of the agreement. If there is a dispute between the client and the third party, the attorney must retain the funds in trust until the resolution of the dispute. Reconciliation Recordkeeping must be coupled with regular reconciliation. Reconciliation means checking the records you are required to keep against each other so you can find and correct any mistakes. First, the trust account general ledger (sometimes called a checkbook balance) must match the combined total of the receipts (deposit slips) journal and disbursements (cancelled checks) journal. These must also match the total balance of all of the individual client ledger sheets, which in turn must also match the reconciled bank statement. To make sure that you find and correct bookkeeping mistakes, you must record every client trust account transaction in at least two places: in your individual client ledger, and also in your general ledger/checkbook register. You can check these records against one another, and also against the bank s records. To perform reconciliations, you first identify the beginning cash balance in the trust account. You then add the total receipts and subtract the total disbursements to arrive at the ending cash balance. This is much like balancing your checkbook. Virgin Islands Trust Account Handbook Page 8

9 The goal is to figure out the correct balance for the month you are reconciling (that is, the amount of money that was actually in the account on the last day of the month) and the correct balance as of the date you complete the reconciliation (that is, the amount of money that is actually in the account now) by entering interest, bank charges and mistake corrections into your account journal and client ledgers. In order for the ending cash balance to match the bank statement, adjustments must be made to the bank account statement to account for items such as outstanding checks and deposits that have not yet cleared the bank account. These amounts will be included on your general ledger, but will not yet appear on the bank statement. Finally, and most importantly, you should total all the individual client or third party ledger balances and compare this to the general ledger/checkbook register balance for the trust account. You can create a special client ledger card to account for bank fees and deposits made to cover bank fees. When the total of client ledgers does not exactly match the general ledger balance do not panic. This means you have found a mistake, and that is what reconciliation is for. Since you record every deposit and withdrawal twice, if you systematically compare each entry in the general ledger/checkbook register with the corresponding entry in the client ledger, and check the new balance you entered after each entry, you will always find the mistake. Mistakes When a mistake is discovered, it must be immediately corrected. You should prepare a memo explaining the error and the steps taken to remedy the situation. This memo should be retained with the reconciliation for later reference. Negative balances, whether they are discovered in a client balance or in the current bank balance, must be promptly reimbursed and a written explanation (e.g., for an accounting error) must be included in the records for the trust account. As you go through the bank statement, there are two common of mistakes you may find: 1. A deposit or withdrawal listed on the bank statement that is not in your general ledger/checkbook register. To correct this mistake, go through your canceled checks (if it is a withdrawal) or deposit slips (if it is a deposit) until you find the one that reflects the transaction on the bank statement. If you cannot find a canceled check or deposit slip that matches the entry on the bank statement, contact your banker and ask him or her to help you track down the transaction. DO NOT record the bank statement entry in your records until you verify that the transaction occurred; banks make mistakes, too. Virgin Islands Trust Account Handbook Page 9

10 2. An entry in the bank statement is different from the corresponding entry in the general ledger/checkbook register. You correct this mistake the same way you correct a transaction you forgot to record. First, find the canceled check or deposit slip that shows the transaction to figure out which record is correct the general ledger/checkbook register or the bank statement. If you cannot find a canceled check or deposit slip for this transaction, contact your banker and ask him or her to help you track it down before you make any changes in your records. Sample 3-Way Reconciliation Worksheet RECONCILIATION March 31, 2015 Client s Trust Ledger Balances: CLIENT AMOUNT Client A Ledger Total $2, Client B Ledger Total $ Client C Ledger Total $ Banks Fees Ledger $45.00 TOTAL $2, * Balance per Bank Statement $ ADD: Outstanding Deposits $2, LESS: All Outstanding Checks $75.00 ADJUSTED BALANCE $2, * Trust General Ledger/Check Register Balance as of March 31, 2015 $2, * * These amounts must match. Virgin Islands Trust Account Handbook Page 10

11 Trust Account Checklist The following steps are recommended to fulfill your responsibilities for oversight and to help differentiate between client funds and the lawyer s personal funds which may be attachable: 1. Establish a clear written policy detailing the procedures for all trust account operations. 2. All staff involved in trust account recordkeeping must receive adequate training. 3. If software is used, a manual explaining how the system operates should be prepared and staff with access to the books should receive periodic training. 4. Split recordkeeping responsibilities among different staff to enhance accountability. The person who prepares the checks should not sign the checks. 5. Only licensed attorneys should have signatory authority over the trust account. 6. The trust account checkbook should be kept under lock and key. 7. If the trust accounting software is installed, the program should be password-protected. 8. Use pre-numbered checks, receipts and deposit slips. Investigate and document the cause of any break in numbers. 9. Trust account checks should say Client Trust Account or words of a similar nature. 10. Deposits to the trust account should be made daily. 11. Never transmit money without a written communication. This includes giving written deposit instructions to your staff. 12. Stay tuned-in to your office by asking clients if they have paid with cash, asking if a receipt was provided, etc. 13. Receipts should be deposited intact to the trust account. 14. Retain detailed records of each deposit. 15. Withdrawals from the trust account must be made to named payees, and not to cash. 16. Earned fees must be promptly removed, and cannot be parked in the trust account. Typically fees should be withdrawn after the client has had an opportunity to review the billing statement and make any objections. 17. All funds must be disbursed promptly. 18. All checks presented for signature should be accompanied by documentation. 19. Never pay personal or office expenses with a trust account check, even if it is earned. 20. Prior to signing a check, client ledger balances should be verified. 21. Never sign blank checks or checks made out to cash. 22. Regularly review client ledgers to ensure there are no negative balances and to ensure funds are not held after the representation ends. 23. Be the first to review monthly bank statements for irregularities. 24. All voided or unused checks should be periodically reviewed. 25. Reconcile the trust account at least monthly and retain all quarterly reconciliations. 26. Review and sign the reconciliation yourself. 27. Complete trust account records must be maintained for five years. 28. An annual audit by a certified public accountant should be considered. Virgin Islands Trust Account Handbook Page 11

12 APPENDIX A Selected Virgin Islands Rules of Professional Conduct Fees (a) A lawyer shall not make an agreement for, charge, or collect an unreasonable fee or an unreasonable amount for expenses. The factors to be considered in determining the reasonableness of a fee include the following: (1) the time and labor required, the novelty and difficulty of the questions involved, and the skill requisite to perform the legal service properly; (2) the likelihood, if apparent to the client, that the acceptance of the particular employment will preclude other employment by the lawyer; (3) the fee customarily charged in the locality for similar legal services; (4) the amount involved and the results obtained; (5) the time limitations imposed by the client or by the circumstances; (6) the nature and length of the professional relationship with the client; (7) the experience, reputation, and ability of the lawyer or lawyers performing the services; and (8) whether the fee is fixed or contingent. (b) The scope of the representation and the basis or rate of the fee and expenses for which the client will be responsible shall be communicated to the client, preferably in writing, before or within a reasonable time after commencing the representation, except when the lawyer will charge a regularly represented client on the same basis or rate. Any changes in the basis or rate of the fee or expenses shall also be communicated to the client. (c) A fee may be contingent on the outcome of the matter for which the service is rendered, except in a matter in which a contingent fee is prohibited by paragraph (d) or other law. A contingent fee agreement shall be in a writing signed by the client and shall state the method by which the fee is to be determined, including the percentage or other percentages that shall accrue to the lawyer in the event of settlement, trial or appeal; litigation and other expenses to be deducted from the recovery; and whether such expenses are to be deducted before or after the contingent fee is calculated. The agreement must clearly notify the client of any expenses for which the client will be liable whether or not the client is the prevailing party. Upon conclusion of a contingent fee matter, the lawyer shall provide the client with a written statement stating the outcome of the matter and, if there is a recovery, showing the remittance to the client and the method of its determination. (d) A lawyer shall not enter into an arrangement for, charge, or collect: (1) any fee in a domestic relations matter, the payment or amount of which is contingent upon the securing of a divorce or upon the amount of alimony or support, or property settlement in lieu thereof; or (2) a contingent fee for representing a defendant in a criminal case. (e) A division of a fee between lawyers who are not in the same firm may be made only if: (1) the division is in proportion to the services performed by each lawyer or each lawyer assumes joint responsibility for the representation; (2) the client agrees to the arrangement, including the share each lawyer will receive, and the agreement is confirmed in writing; and (3) the total fee is reasonable. Virgin Islands Trust Account Handbook Page 12

13 Safekeeping Property: Generally (a) A lawyer shall hold property of clients or third persons that is in a lawyer s possession in connection with a representation separate from the lawyer's own property. Funds shall be kept in a separate account maintained in the state where the lawyer's office is situated, or elsewhere with the consent of the client or third person. Other property shall be identified as such and appropriately safeguarded. Complete records of such account funds and other property shall be kept by the lawyer and shall be preserved for a period of five years after termination of the representation. (b) A lawyer may deposit the lawyer s own funds in a client trust account for the sole purpose of paying bank service charges on that account, but only in an amount necessary for that purpose. (c) A lawyer shall deposit into a client trust account legal fees and expenses that have been paid in advance, to be withdrawn by the lawyer only as fees are earned or expenses incurred. (d) Upon receiving funds or other property in which a client or third person has an interest, a lawyer shall promptly notify the client or third person. Except as stated in this Rule or otherwise permitted by law or by agreement with the client, a lawyer shall promptly deliver to the client or third person any funds or other property that the client or third person is entitled to receive and, upon request by the client or third person, shall promptly render a full accounting regarding such property. (e) When in the course of representation a lawyer is in possession of property in which two or more persons (one of whom may be the lawyer) claim interests, the property shall be kept separate by the lawyer until the dispute is resolved. The lawyer shall promptly distribute all portions of the property as to which the interests are not in dispute Client Trust Account Records (a) A lawyer who practices in this jurisdiction shall maintain current financial records as provided in these Rules and required by Rule , and shall retain the following records for a period of five years after termination of representation: (1) receipt and disbursement journals containing a record of deposits to and withdrawals from client trust accounts, specifically identifying the date, source, and description of each item deposited, as well as the date, payee and purpose of each disbursement; (2) ledger records for all client trust accounts showing, for each separate trust client or beneficiary, the source of all funds deposited, the names of all persons for whom the funds are or were held, the amount of such funds, the descriptions and amounts of charges or withdrawals, and the names of all persons or entities to whom such funds were disbursed; (3) copies of retainer and compensation agreements with clients, as required by Rule ; (4) copies of accountings to clients or third persons showing the disbursement of funds to them or on their behalf; (5) copies of bills for legal fees and expenses rendered to clients; Virgin Islands Trust Account Handbook Page 13

14 (6) copies of records showing disbursements on behalf of clients; (7) the physical or electronic equivalents of all checkbook registers, bank statements, records of deposit, pre-numbered canceled checks, and substitute checks provided by a financial institution; (8) records of all electronic transfers from client trust accounts, including the name of the person authorizing transfer, the date of transfer, the name of the recipient and confirmation from the financial institution of the trust account number from which money was withdrawn and the date and the time the transfer was completed; (9) copies of monthly trial balances and quarterly reconciliations of the client trust accounts maintained by the lawyer; and (10) copies of those portions of client files that are reasonably related to client trust account transactions. (b) With respect to client trust accounts required by Rule (a): (1) only a lawyer admitted to practice law in this jurisdiction or a person under the direct supervision of the lawyer shall be an authorized signatory or authorize transfers from a client trust account; (2) receipts shall be deposited intact and records of deposit should be sufficiently detailed to identify each item; and (3) withdrawals shall be made only by check payable to a named payee and not to cash, or by authorized electronic transfer. (c) Records required by this Rule may be maintained by electronic, photographic, or other media provided that they otherwise comply with these Rules and that printed copies can be produced. These records shall be readily accessible to the lawyer. (d) Upon dissolution of a law firm or of any legal professional corporation, the partners shall make reasonable arrangements for the maintenance of client trust account records specified in Rule (a). (e) Upon the sale of a law practice, the seller shall make reasonable arrangements for the maintenance of records specified in Rule (a) Client Files (a) For purposes of this Rule, a client s file shall consist of any documents, electronic and print format, writings, or property provided by the client or derived in the course of representation of the client, except: (1) Lawyer s notes, impressions, internal memoranda, legal research and factual research, including investigative reports, prepared by or for the lawyer s use in the representation; and (2) Documents that have not been filed with a tribunal, delivered, or served, unless the client has explicitly paid for the drafting or creation thereof; and (3) Other drafted but unexecuted or undelivered documents, unless the client has explicitly paid for the drafting or creation thereof. Virgin Islands Trust Account Handbook Page 14

15 (b) Upon the client s request, the lawyer shall surrender the client s file. The lawyer may charge the client reasonable costs for reproduction and retrieval if: (1) The lawyer had previously provided copies of any part of the file to the client, in which case the lawyer may only charge for that portion of the file that was previously provided; and (2) The charge does not prejudice the interests of a client in a matter that is currently pending. (c) The lawyer may, at no charge to the client, retain copies of all documents within the client s file. (d) A lawyer must maintain the client s file for 10 years after the conclusion of representation in a matter unless the lawyer delivers the file to the client or the client authorizes destruction of the file in a writing signed by the client, provided the time for appeal has expired and there are no pending or threatened legal proceedings known to the lawyer that relate to the matter. (e) At any time following the expiration of 10 years following the conclusion of the representation in a matter, a lawyer may destroy the client s files respecting the matter, provided the lawyer has provided reasonable notice to the client and there are no pending or threatened legal proceedings known to the lawyer that relate to the matter. (f) Notwithstanding Rules (d) and (e), a lawyer in a criminal matter must maintain the client s file for the life of the client if the mater resulted in a conviction and a sentence of death, natural life, life without parole, or an indeterminate sentence. (g) This Rule does not supersede or limit a lawyer s obligations to retain or destroy contents of a client s file as otherwise imposed by law, court order, or rules of a tribunal. (h) To protect the client s interest in case of lawyer death or incapacity, a lawyer should prepare a plan for succession. The plan must include, but is not limited to, the designation of another lawyer to act as successor counsel who is authorized to review client files, notify clients of the lawyer s death or incapacity, and act if immediate action on the client file is necessary to protect the client s interests. The designated lawyer should agree, in writing, to the assignment as successor counsel. Lawyers in a law firm of two or more lawyers may follow established firm guidelines for succession in lieu of designation of successor counsel. (i) Upon dissolution of a law firm or of any legal or professional corporation, or sale of a law practice, the partners or shareholders shall make reasonable arrangements for client files in accordance with Rules (d)-(g). Virgin Islands Trust Account Handbook Page 15