Yes, you can fill out California Form GC-400 yourself by listing every asset the protected person owned on the date the conservatorship or guardianship started, separating cash from non-cash items, and sending the non-cash items to a court-appointed Probate Referee for appraisal. The form is the official Inventory and Appraisal cover sheet that the conservator, guardian of the estate, or personal representative files to tell the court exactly what is in the estate.
You must file it within 90 days of your appointment under Probate Code § 2610, and missing that deadline can lead to surcharges, removal, or even personal liability. According to the Judicial Council of California 2024 Court Statistics Report, California courts process more than 42,000 active conservatorship and guardianship cases each year, and inventory errors are one of the top three reasons for rejected filings.
Here is what you will learn in this guide:
- 📋 How to complete every line of GC-400 and its attachments without rejection
- ⚖️ Which assets count as cash versus non-cash and why the split matters
- 💰 How the Probate Referee appraises property and charges fees
- 🗓️ How to meet the 90-day deadline and request extensions the right way
- 🚫 The seven mistakes that get inventories bounced back by the clerk
What Form GC-400 Is and Why It Exists
Form GC-400, titled Inventory and Appraisal, is the cover sheet that opens every estate inventory filed in a California guardianship or conservatorship case. It is published by the Judicial Council of California and is mandatory in every county. The form gives the court, the protected person, and any interested parties a sworn snapshot of the estate on the date the fiduciary took office.
The form pairs with several attachments that do the actual listing work. The cover page only carries totals, the appointment information, and the appraisal declarations. The attachments — GC-040 Attachment 1 for cash items and GC-040 Attachment 2 for non-cash items — carry the asset-by-asset details. You can find the full attachment in the GC-040 form packet on the Judicial Council site.
The legal foundation for GC-400 is Probate Code §§ 2610–2616 for conservatorships and guardianships, plus Probate Code §§ 8800–8920 for decedent estates that share the same inventory rules. California Rules of Court, Rule 7.1003 sets the formatting expectations every clerk follows.
The why behind GC-400 is accountability. The court cannot supervise a fiduciary if it does not know what assets are in the estate. The consequence of a sloppy or late inventory is that the court loses confidence in the fiduciary, and that loss of confidence often leads to bond increases, status hearings, or removal under Probate Code § 2650.
A common misconception is that GC-400 is only for big estates. It is not. Even a guardianship of a minor with only a $5,000 settlement check must file GC-400, because the duty attaches to the office, not the dollar amount.
Guardianship vs. Conservatorship Use
Guardianship of the estate covers minors under 18 who own assets, while conservatorship of the estate covers adults who cannot manage their own finances. Both fiduciaries use the same GC-400 because the inventory duty under Probate Code § 2610 is identical.
The differences show up in the captions and the attachments. A guardian writes Guardianship of (Name), a Minor in the caption, while a conservator writes Conservatorship of the Person and Estate of (Name) or Conservatorship of the Estate of (Name). The case category checkbox at the top of GC-400 changes too.
The consequence of checking the wrong box is a bounced filing and lost time. Imagine Maria Lopez, a guardian for her nephew, who checks the conservatorship box by accident. The clerk rejects the filing, the 90-day clock keeps ticking, and Maria has to refile and explain the delay at the next status hearing.
Who Must File GC-400 and When
Every conservator of the estate, guardian of the estate, and personal representative of a decedent estate must file GC-400. The duty arises the moment the Letters of Conservatorship or Letters of Guardianship are issued. The clock does not wait for the fiduciary to feel ready.
The deadline is 90 calendar days from the date the Letters issue, set by Probate Code § 2610(a). The court can extend the deadline only on a noticed motion or stipulation that shows good cause. Many fiduciaries file a Form GC-020 Notice of Hearing bundled with a request for additional time.
The consequence of missing 90 days without an extension is real. The court can issue an order to show cause, surcharge the fiduciary for any loss caused by the delay, increase the bond, or remove the fiduciary entirely. In re Conservatorship of Kane (2006) 137 Cal.App.4th 400 recaps how a delayed inventory contributed to fiduciary surcharge.
A quick scenario shows the stakes. David Chen is appointed conservator on January 10. His inventory is due April 10. If he files on April 25 with no extension, the judge can order David to personally pay any market loss the estate suffered between April 10 and April 25.
A common misconception is that a partial inventory tolls the deadline. It does not. A Partial Inventory must still be filed by the 90-day mark, with a Final Inventory filed within one year under Probate Code § 2613.
Line-by-Line Walkthrough of GC-400
The cover page of GC-400 has six numbered items, a caption block, and a signature block. Each line carries a specific legal meaning, and each box you check or skip changes how the court reads your filing. Walk through each item slowly the first time you fill it out.
Caption Block
The caption block sits at the very top. You enter the attorney or self-represented filer information, the court branch, and the case name and number. The case name must match the Letters exactly, including punctuation, because the clerk indexes the filing by that string.
The consequence of mismatched captions is a Notice of Rejection from the clerk. Sarah Patel, a paralegal in Orange County, lost three days when she typed Conservatorship of Estate of Robert Kim instead of the correct Conservatorship of the Person and Estate of Robert Kim. The clerk rejected the filing and Sarah had to courier a corrected copy.
A common misconception is that the address line is for the protected person. It is not. The address belongs to the filer, because that is where the court mails minute orders and rejection notices.
Item 1: Type of Inventory
Item 1 forces you to pick one of four checkboxes — Partial No., Final, Supplemental, or Reappraisal for Sale. A Partial is your first cut when some assets are still being identified. A Final is the comprehensive inventory that closes the listing duty. A Supplemental covers assets discovered later, and a Reappraisal for Sale updates value before a court-confirmed sale under Probate Code § 10309.
Choosing the wrong type causes timing problems. A Final filed before all assets are listed forces you to file a Supplemental later, which doubles the Probate Referee fees. The right move when assets are still being traced is Partial No. 1, then Final once everything is in.
Item 2: Property Tax Certificate
Item 2 is a tiny but high-stakes checkbox. It states that the personal representative has filed (or will file) a change-in-ownership statement with the county assessor under Revenue and Taxation Code § 480. It applies only when real property is in the estate.
The consequence of skipping this checkbox when real estate is involved is a hold by the court and possible reassessment penalties from the assessor. Conservators often miss this because conservatorship usually does not trigger a change in ownership, but the box must still be checked to confirm the filing decision.
Item 3: Total Appraisal by Representative
Item 3 holds the cash total. The representative — meaning you, the conservator or guardian — appraises cash items yourself. Cash items include currency, bank balances, money market accounts, certificates of deposit, refund checks, and the proceeds of matured insurance policies under Probate Code § 8901.
The number you write here must equal the sum on Attachment 1. A mismatch is the single most common reason inventories are rejected. Use a calculator twice and reconcile to the penny before filing.
Item 4: Total Appraisal by Referee
Item 4 holds the non-cash total. The Probate Referee — a state-appointed appraiser — fills in this number after appraising the items on Attachment 2. The referee signs the form and returns it to you for filing.
The consequence of writing your own estimate here is automatic rejection. Only the Probate Referee can value non-cash assets unless the court has waived the referee under Probate Code § 8903.
Items 5 and 6: Declarations and Bond
Item 5 is the Declaration of Personal Representative, and Item 6 is the Statement Regarding the Bond. Item 5 swears under penalty of perjury that the inventory is complete to your knowledge. Item 6 confirms that the bond on file is enough to cover the inventory total plus one year of estimated income.
If the bond is not enough, you must request an increase before or with the inventory. Skipping this step exposes you to personal liability if the estate is later mishandled. James O’Brien, a guardian in Sacramento, learned this when his bond was $50,000 but the inventory came in at $310,000. The court ordered an immediate bond increase and a status hearing.
Cash vs. Non-Cash: The Big Split
The cash versus non-cash split drives the entire inventory process. The split decides who appraises the asset, what fee the estate pays, and how fast the inventory closes. Probate Code § 8901 defines cash items narrowly, and everything else is non-cash by default.
Cash items include currency, accounts in banks and credit unions, brokerage cash balances, money market funds, certificates of deposit, and the face value of refund checks. The fiduciary appraises these at the date-of-death or date-of-appointment balance. Statements pulled from each institution should match the inventory dollar for dollar.
Non-cash items include real estate, vehicles, jewelry, collectibles, business interests, stocks, bonds, mutual funds, mineral rights, promissory notes, and life insurance with no fixed maturity value. These go on Attachment 2 and travel to the Probate Referee for appraisal under Probate Code § 8902.
A common misconception is that publicly traded stocks count as cash because they trade like cash. They do not. Stocks are non-cash because their value moves daily and a neutral appraisal is required.
Attachment 1 — Cash Items
Attachment 1 is a numbered list. Item 1 might read Wells Fargo checking account #1234, balance on 1/10/2026: $4,217.55. Item 2 might read *Vanguard money market fund #*5678, balance on 1/10/2026: $22,140.10. Each item gets its own line, its own description, and its own dollar value.
The consequence of vague descriptions is a request for further information by the court investigator. Always include the institution name, the last four digits of the account, and the date of the balance. The total at the bottom of Attachment 1 must match Item 3 on the cover sheet exactly.
Attachment 2 — Non-Cash Items
Attachment 2 lists everything else. Real property gets the legal description, the assessor’s parcel number, and the street address. Vehicles get the year, make, model, VIN, and mileage. Securities get the ticker symbol, share count, and CUSIP number when available.
The Probate Referee writes the appraised value next to each item and signs the attachment. The total at the bottom must match Item 4 on the cover sheet. Detail matters because the referee cannot appraise what is not described, and missing detail leads to follow-up letters that delay the filing.
The Probate Referee Process
The Probate Referee is a non-judicial appraiser appointed by the State Controller under Probate Code § 400. One referee is assigned to each case at the time the Letters issue. You can find the assigned referee by checking the California Probate Referees Association directory or the order appointing the referee in the case file.
The referee receives Attachment 2 from the fiduciary, performs the appraisal, signs the inventory, and returns the package. The referee may ask for supporting documents — deeds, statements, photographs, business tax returns, or appraisals from specialists for art and jewelry. The referee may also visit real property when needed.
The fee is set by Probate Code § 8961 at 0.1% of the total appraised value, with a minimum fee of $75 and a maximum of $10,000 per estate, plus reasonable expenses. A $1 million estate pays $1,000. A $50,000 estate pays $75 because the minimum kicks in.
The consequence of trying to bypass the referee without a court waiver is rejection of the inventory. A waiver is rare and is granted only on noticed motion under Probate Code § 8903 when, for example, the estate has only depository accounts and a single insurance policy with cash value.
A common misconception is that the referee charges by the hour. They do not. The flat 0.1% rule controls, which means complex appraisals are sometimes a bargain and simple ones can feel pricey.
Three Real-World Scenarios
Three scenarios show how the rules play out for ordinary California families. Each is presented as a two-column table that pairs the action with the legal consequence. These tables turn abstract rules into practical decisions.
Scenario 1: Daughter Conservator with Mixed Assets
Linda Park is appointed conservator of the estate of her 82-year-old mother in Los Angeles County on March 1. Her mother owns a Pasadena home, a Charles Schwab brokerage account, a Bank of America checking account, and a 2018 Toyota Camry.
| Action Linda Takes | Legal Consequence |
|---|---|
| Files GC-400 by May 30 | Meets the 90-day deadline under Probate Code § 2610 |
| Lists Schwab account on Attachment 2 | Securities get a referee appraisal because they are non-cash |
| Lists checking balance on Attachment 1 | Bank balances are cash items appraised by Linda |
| Includes APN for Pasadena home | Referee can appraise without a follow-up letter |
| Files Form GC-020 for bond increase | Avoids personal liability if estate exceeds bond |
Scenario 2: Guardian of a Minor with Settlement Funds
Andre Williams is appointed guardian of the estate of his 9-year-old nephew, who received $180,000 from a wrongful-death settlement. The funds sit in a blocked account at a credit union.
| Action Andre Takes | Legal Consequence |
|---|---|
| Lists blocked account on Attachment 1 | Settlement funds in a depository are cash items |
| Files inventory at $180,000 even though blocked | Inventory captures all assets regardless of access |
| Requests referee waiver under § 8903 | Waiver may be granted because all assets are cash |
| Confirms bond per Probate Code § 2320 | Blocked accounts often reduce bond requirement |
| Files within 90 days | Avoids surcharge and order to show cause |
Scenario 3: Professional Fiduciary with Multi-County Real Estate
Patricia Nguyen, a licensed professional fiduciary, is appointed conservator of an adult with real property in San Diego, Riverside, and Marin counties. Each county has its own Probate Referee.
| Action Patricia Takes | Legal Consequence |
|---|---|
| Files in the county where conservatorship sits | Single inventory covers all real property statewide |
| Sends Attachment 2 to the assigned referee | One referee handles all parcels under Prob. Code § 400 |
| Files change-in-ownership with each county | Avoids reassessment penalties under Rev. & Tax. § 480 |
| Files Partial No. 1 within 90 days | Buys time to trace out-of-state assets |
| Files Final within one year | Closes inventory duty under Probate Code § 2613 |
Three Named Examples in Detail
Three named examples bring the rules to ground level. Each example follows a single fiduciary through a real choice point. The names are illustrative.
Example 1: Maria Hernandez and the Forgotten Brokerage Account
Maria Hernandez is appointed conservator of her uncle’s estate in Fresno County. She files GC-400 listing his Wells Fargo checking account and his Camry, total $48,000. Three months later, she finds an old E*TRADE account worth $62,000.
Maria files a Supplemental Inventory using a fresh GC-400 with Item 1 marked Supplemental. She sends Attachment 2 to the Probate Referee and pays an extra $62 in referee fees. The court accepts the supplemental and Maria avoids any surcharge because she acted promptly under Probate Code § 2613.
Example 2: Robert Kim and the Pasadena Bungalow
Robert Kim is appointed conservator for his mother. Her bungalow is worth roughly $1.2 million. Robert lists the bungalow on Attachment 2 with the full legal description, the APN, and the address.
The Probate Referee appraises the bungalow at $1,185,000 and charges $1,185 in fees under the 0.1% rule. Robert files the inventory at day 88 of the 90-day window. He also files the change-in-ownership statement with the Los Angeles County Assessor to avoid reassessment penalties.
Example 3: Jasmine Wright and the Coin Collection
Jasmine Wright is guardian of her 12-year-old daughter’s estate, which includes a coin collection inherited from her grandfather. Jasmine cannot estimate the coin value herself.
She lists the coins on Attachment 2 with detailed descriptions — year, mint, grade, and quantity — and ships the collection to the Probate Referee. The referee retains a numismatist specialist, charges Jasmine the specialist’s fee plus the 0.1% statutory fee, and returns an appraisal of $14,500. Jasmine files the inventory, and the court approves it without comment.
County-Specific Quirks
California has 58 counties, and each Superior Court has small twists on the same form. Knowing your county’s quirks saves rejections.
In Los Angeles County, the Probate Division requires inventories to be filed at Stanley Mosk Courthouse and uses a dedicated examiner who flags missing APNs immediately. In Orange County, the Probate Court uses an electronic filing portal and rejects PDFs over 25 MB. In San Diego County, the Probate Court requires the Probate Referee’s original signature in blue ink on the cover sheet. In San Francisco County, the Probate Department wants a courtesy copy delivered to the court investigator within five days of filing.
The consequence of missing a county quirk is a bounced filing or a Notice to Correct. Always check the local rules page of the assigned court before submission.
Mistakes to Avoid
Below are the seven mistakes that get inventories bounced or surcharged. Each mistake comes with the negative outcome that follows.
- Filing past 90 days with no extension triggers an order to show cause and possible surcharge under Probate Code § 2610.
- Mixing cash and non-cash on the wrong attachment causes the Probate Referee to reject the package and request a corrected Attachment 2.
- Self-appraising stocks or real estate is unauthorized and leads to outright rejection unless a § 8903 waiver is on file.
- Writing vague asset descriptions like bank account or the house forces follow-up letters and delays the appraisal.
- Forgetting the change-in-ownership statement with real property triggers reassessment and county penalties under Rev. & Tax. Code § 480.
- Mismatched totals between Attachment 1 and Item 3, or Attachment 2 and Item 4, are the top reason for clerk rejections.
- Skipping the bond review in Item 6 exposes the fiduciary to personal liability if the inventory exceeds the bond.
- Failing to sign the declaration in Item 5 voids the entire filing because an unsigned inventory is not under oath.
- Listing assets at the wrong valuation date — for example, today’s date instead of the date of appointment — distorts the inventory and forces a correction.
Dos and Don’ts
A simple list of dos and don’ts keeps you on the rails. Each entry includes the why behind the rule.
Dos
- Do pull every account statement for the date of appointment, because that is the legal valuation date.
- Do call the Probate Referee early, because their cooperation speeds the appraisal.
- Do file a Partial No. 1 if you cannot finish in 90 days, because partials stop the surcharge clock.
- Do keep a workpaper that ties Attachment 1 and Attachment 2 totals to the cover sheet, because clerks check the math.
- Do review the bond against the new total, because an under-bonded fiduciary is personally exposed.
Don’ts
- Don’t estimate non-cash values, because only the referee can appraise them.
- Don’t abbreviate institution names, because clerks and investigators rely on exact identifiers.
- Don’t delete an asset after listing it, because amendments require a Supplemental, not a deletion.
- Don’t forget the change-in-ownership filing, because the assessor charges penalties even when the conservatorship is exempt.
- Don’t file the cover sheet without the referee’s signature, because an unsigned cover is invalid.
Pros and Cons of Self-Filing GC-400
Filing GC-400 without an attorney has trade-offs. Here are five of each side, with the why behind every point.
Pros
- Cost savings of $1,500 to $4,000 in attorney fees on a typical estate, because GC-400 is a form-driven filing.
- Direct knowledge of the protected person’s assets, because family members often spot accounts attorneys miss.
- Faster turnaround when you control your own calendar, because attorney bottlenecks are removed.
- Better continuity with later accountings, because the same person knows the asset history.
- Confidence building for ongoing fiduciary duties, because filing the inventory teaches the rules.
Cons
- Higher rejection risk because clerks scrutinize pro se filings closely.
- Personal liability exposure because mistakes fall on you, not on counsel’s malpractice carrier.
- Time burden of 10 to 25 hours, because tracing assets is slow.
- Tax pitfalls with change-in-ownership and basis step-up, because these rules are not on the form itself.
- No coverage for unusual assets like business interests, where attorney input pays for itself.
Key Entities You Will Meet
The GC-400 process pulls in several key players. Knowing each role helps you route questions correctly.
The Superior Court Probate Department receives the filing and rules on it. The Court Investigator, a court-employed neutral, reviews conservatorship filings and reports to the judge under Probate Code § 1826. The Probate Referee appraises non-cash assets under Probate Code § 8902. The County Assessor processes change-in-ownership filings.
The Judicial Council of California publishes and revises GC-400 itself. The California Department of Consumer Affairs Professional Fiduciaries Bureau licenses and regulates professional fiduciaries who often serve as conservators. The State Controller appoints Probate Referees under Probate Code § 400.
These entities relate to one another like a relay. The fiduciary hands the baton to the referee, the referee returns it signed, the fiduciary hands it to the clerk, the clerk passes it to the investigator and judge, and the judge approves or sends it back.
Recap of Relevant Court Rulings
A few California rulings shape how courts read GC-400 filings. Each ruling carries a practical lesson.
In Conservatorship of Kane (2006) 137 Cal.App.4th 400, the court affirmed surcharge against a conservator whose late and incomplete inventory contributed to estate loss. The lesson is that delay plus incompleteness equals personal liability.
In Estate of Bonaccorsi (1999) 69 Cal.App.4th 462, the court emphasized that the Probate Referee’s appraisal is presumptively correct and shifts the burden to any objector. The lesson is that challenging a referee’s value requires evidence, not opinion.
In Conservatorship of Lewis (1981) 116 Cal.App.3d 169, the court reminded fiduciaries that the inventory duty is independent of the accounting duty. The lesson is that filing an account does not cure a missing inventory.
How to File and Serve GC-400
Filing GC-400 has three steps — assemble, sign, and serve. Skipping any step delays acceptance.
Step 1 — Assemble the cover sheet, Attachment 1, Attachment 2, the referee’s signed appraisal, and any change-in-ownership statement. Step 2 — Sign Item 5 under penalty of perjury and confirm the referee’s signature on the cover. Step 3 — Serve copies on the protected person, the protected person’s attorney if any, the spouse or registered domestic partner, and any party who requested special notice under Probate Code § 2700.
The consequence of skipping service is that the inventory may be deemed not filed for due-process purposes, and the court can order re-service. Use a Form POS-030 Proof of Service by Mail to document delivery.
Frequently Asked Questions
Do I have to file GC-400 if my conservatee has only a checking account?
Yes. Even a single account triggers the inventory duty under Probate Code § 2610, and you must file GC-400 with Attachment 1 within 90 days of your appointment.
Can I appraise my mother’s house myself to save the referee fee?
No. Real property is a non-cash asset, and only a Probate Referee may appraise it unless the court grants a § 8903 waiver, which is rare for real estate.
Is the Probate Referee fee negotiable?
No. The fee is set by statute at 0.1% of appraised value, with a $75 minimum and a $10,000 maximum, plus reasonable expenses under Probate Code § 8961.
Can I file GC-400 electronically?
Yes. Most large California counties accept electronic filing through providers like One Legal or File and ServeXpress, but smaller counties may still require paper or paper-plus-PDF filings.
Do I need to list the conservatee’s Social Security check?
Yes. The current month’s deposited SSA payment counts as a cash item on Attachment 1 if it sits in a bank account on the date of appointment, but future payments are income, not inventory.
What if I discover an asset after I file the Final Inventory?
Yes, you must file a Supplemental Inventory using a fresh GC-400 marked Supplemental in Item 1, with the new asset on the appropriate attachment and a fresh referee appraisal if non-cash.
Can I get the 90-day deadline extended?
Yes. The court can extend the deadline on a noticed motion showing good cause, such as out-of-state assets or uncooperative third parties holding records.
Do household furnishings need to be listed?
Yes, household furnishings are non-cash items on Attachment 2, but routine household goods can usually be lumped together as one line item with a single referee appraisal.
Is a vehicle a cash or non-cash item?
No, a vehicle is never cash; it is a non-cash item on Attachment 2 because its value is set by market data, and the Probate Referee uses guides like Kelley Blue Book.
Do I need an attorney to file GC-400?
No. Self-represented conservators and guardians can file GC-400, but complex estates with business interests, real estate in multiple states, or trust assets are usually worth an attorney consult.
Does GC-400 cover trust assets?
No. Assets held in a revocable or irrevocable trust are not part of the conservatorship or guardianship estate and do not go on GC-400 unless the court has ordered them brought into the estate.
What happens if my totals do not match?
No, mismatched totals are not accepted; the clerk will reject the filing and you must correct Attachment 1, Attachment 2, or the cover sheet so each subtotal matches Item 3 and Item 4 to the penny.
Related reading
- How to Fill Out California Form DE-160 (w/Examples) + FAQs
- How to Fill Out California Form GC-110 (w/Examples) + FAQs
- How to Fill Out California Form GC-150 (w/Examples) + FAQs
- How to Fill Out California Form GC-200 (w/Examples) + FAQs
- How to Fill Out California Form GC-250 (w/Examples) + FAQs
- How to Fill Out California Form GC-320 (w/Examples) + FAQs