(a) A trustee may file an accounting of the trustee’s administration of a trust in court at any time and seek a partial or final settlement thereof or, upon petition of an interested party, a court may order a trustee to render an accounting of the trustee’s administration of a trust and require a partial or final settlement thereof. Notice of such judicial proceeding shall be provided to the trustee and each beneficiary, or representative thereof pursuant to Article 3, as provided by the applicable rules of civil procedure.
(b) A trust accounting must be a reasonably understandable report from the date of the last accounting or, if none, from the date upon which the trustee became accountable, or other such date the court may set, which provides reasonable detail of the transactions affecting the administration of the trust, and which adequately discloses the following information:
(1) The accounting must identify the trust, the trustee furnishing the accounting, and the time period covered by the accounting.
(2) The accounting must show all receipts and disbursements occurring during the accounting period. Gains and losses realized during the accounting period must also be shown.
(3) The accounting, to the extent feasible, must identify and value trust assets on hand at the close of the accounting period. For each asset or class of assets reasonably capable of valuation, the accounting shall contain two values, (i) the asset acquisition value or carrying value, and (ii) the estimated current value, if feasible. The accounting must identify each known noncontingent liability with an estimated current amount of the liability if known.
(4) To the extent feasible, the accounting must show the significant non-cash transactions affecting the assets of the trust, including name changes in investment holdings, adjustments to carrying value, or stock splits.
(5) The accounting must reflect the allocation of receipts and disbursements between income and principal when the allocation affects the interest of any beneficiary of the trust.
(c) Any order or judgment of the court on such accounting and partial or final settlement shall be final and conclusive as to all matters occurring during the accounting period, and appeals therefrom shall and must be taken in the manner provided for from any other final judgment of the court.
(Act 2006-216, p. 314, §1.)
Notes of Decisions
Cited in
7
cases (
1 in the last 5 years), 2010–2025 · leading case:
Bates v. Stewart, 99 So. 3d 837 (Ala. 2012).
Bates v. Stewart, 99 So. 3d 837 (Ala. 2012).
· cites it 4× “They continued to request an accounting of the settlement proceeds in addition to an accounting of the Abernathy trust pursuant to § 19-3B-205, and they alleged that “[t]he Abernathy Trust Foundation is a trust organized under the laws of the State of New York and funded by…”
Regions Bank v. Reed, 60 So. 3d 868 (Ala. 2010).
· cites it 2× “” On November 19, 2008, Regions filed a “Petition for Final Settlement” in the probate court (“the final-settlement action”) pursuant to § 19-3B-205, Ala.Code 1975, 1 concerning the trusts for which it served as trustee or eotrustee: the Father Trust, the Mother Trust created…”
Regions Bank v. Kramer, 98 So. 3d 510 (Ala. 2012).
“[[Image here]] “On November 19, 2008, Regions filed a ‘Petition for Final Settlement’ in the probate court (‘the final-settlement action’) pursuant to § 19-3B-205, Ala. Code 1975, concerning the trusts for which it served as trustee or cotrustee [[Image here]] “On November 20,…”
Bates v. Stewart, 256 So. 3d 72 (Ala. 2018).
· cites it 4× “George Bates and David Joyner appeal from an order of the Etowah Circuit Court approving a final judicial accounting of the administration of a trust pursuant to § 19-3B-205, Ala. Code 1975. We dismiss the appeal.”
Blacklidge v. Anderson (N.D. Ala. 2025).
· cites it 3× “However, Blacklidge proceeds under § 19-3B-813(d), not § 19-3B-205. Anderson states she “will obviously comply with any judicial order directing that such an accounting be provided to the court.”
Ala. Code § 19-3B-205(a): 5 cases
Bates v. Stewart, 99 So. 3d 837 (Ala. 2012).
“They continued to request an accounting of the settlement proceeds in addition to an accounting of the Abernathy trust pursuant to § 19-3B-205, and they alleged that “[t]he Abernathy Trust Foundation is a trust organized under the laws of the State of New York and funded by…”
Blacklidge v. Anderson (N.D. Ala. 2025).
“However, Blacklidge proceeds under § 19-3B-813(d), not § 19-3B-205. Anderson states she “will obviously comply with any judicial order directing that such an accounting be provided to the court.”
Bates v. Stewart, 256 So. 3d 72 (Ala. 2018).
“George Bates and David Joyner appeal from an order of the Etowah Circuit Court approving a final judicial accounting of the administration of a trust pursuant to § 19-3B-205, Ala. Code 1975. We dismiss the appeal.”
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