That behavior qualifies as a bug IMHO also, Bob.
I have listed it here:
http://allenbrowne.com/Access2007.html#Bugs
Hopefully it will be fixed in a serivce pack.
In the mean time, the only workaround I am aware of is to redesign the form
so it does not use a subform for the rich text.
You might also need to be aware that spell-checking a rich text field will
make a mess of your data if the field contains carriage returns.

Signature
Allen Browne - Microsoft MVP. Perth, Western Australia
Tips for Access users - http://allenbrowne.com/tips.html
Reply to group, rather than allenbrowne at mvps dot org.
> I am using Access 2007 and have a rich text field in a subform. When
> the subform is opened directly the toolbars for formatting function
[quoted text clipped - 7 lines]
> Cheers
> Bob