MEMORANDUM

TO: Members, Virginia Joint Commission to Study Multidisciplinary Practices (MDPs)
FROM: James M. McCauley, Ethics Counsel
RE: Summary Report on Activity by Bars Studying MDPs
DATE: August 21, 2000

 

Introduction

I hope that this memorandum will prove a useful summary of the most important and current information concerning the study of MDPs. Time constraints do not permit me to summarize all the material I have collected. My goal was to write something succinct that would likely be read by each Commission member before our first meeting on August 29. I apologize, in advance, if I am stating things which you may already know, but since we have not met as a Commission since January, I do not know how well you have been kept informed on the subject matter. We had a remarkable program on MDPs at the Annual Meeting of the Virginia State Bar in June and I encourage you to see the videotape recording of that program if you were unable to attend.

 

Activity of the American Bar Association

At its annual meeting in August 1999, the ABA House of Delegates debated the recommendations of the ABA Commission on Multidisciplinary Practice in favor of fully integrated MDPs. The House of Delegates ultimately passed a resolution that no changes to the Model Rules of Professional Conduct be made unless and until further study establishes that MDPs would be in the best interests of the public and could exist without compromising the legal profession's core values of independent professional judgment, protecting confidentiality, avoidance of conflicts of interest, competence and loyalty. Since that meeting, many state and local bar associations have appointed task forces to undertake such studies.

At its July 2000 meeting in New York, the ABA House of Delegates adopted Resolution 10F, rejecting the ABA Commission's Recommendations, calling for measures to step up enforcement of current rules and discharging the ABA Commission on MDPs. This measure passed overwhelmingly by a vote of nearly 3 to 1.

 

Activity of other State Bars and Bar Associations

Attached to this summary report is a chart containing information that was available to the ABA Commission as of July 6, 2000. According to this chart:

Twenty-three states have appointed committees but the committees have not yet returned reports.
Ten states have appointed committees that have returned reports but have taken no action on the reports.
Three states have taken favorable action on pro change reports.
Nine states have taken action against change at the Board or House level.
Information has not been available from two states.
Four states have not appointed committees.
Lawyer numbers are based upon 2000 National Lawyer Population Survey of by ABA Market Research Department.

State bars or associations that have spoken in favor of MDPs are: Arizona, Colorado, District of Columbia, Maine, Minnesota , Oregon, South Carolina , South Dakota.

States that have come out opposed to MDPs are: Florida, Illinois, Kansas, Kentucky, Nebraska, New Jersey, New York, Ohio, Pennsylvania, Tennessee, Texas
Activity of the Virginia MDP Commission

The Virginia MDP Commission was appointed in 1999 by past President W. Scott Street, III. The Virginia MDP Commission conducted its first organizational meeting in Williamsburg on January 13, 2000. Due to serious illness, the Commission Chair, Robert Nusbaum was not able to attend the first meeting and further meetings were abated pending report on his health. Mr. John A. C. Keith served as interim Chair and recently was appointed permanent Chair of the Commission after Mr. Nusbaum indicated that he would prefer to serve as a member rather than Chair of the Commission.

A Steering Committee was appointed which met by conference call on August 10, 2000 to assist the Commission in refocusing on its mission. Participating in that conference were: John Keith, Tom Edmonds, Jim McCauley, Tom Spahn, Frank Thomas, Heman Marshall and James White. As a result of this conference some "Working Groups" were established:

  • Ethics/UPL

  • Accountancy Regulation

  • Other Disciplines

  • Effect on Small/Solo Law Firms

  • Education and Communication

  • The European MDP Experience

  • Consumer Demand for MDPs

The primary function of the Ethics/UPL Group is to spot issues and propose solutions as they relate to the ethics and UPL implications of MDPs. The purpose of the Accountancy Regulation Group is to study and inform the rest of the Commission regarding what professional ethics rules apply to accountants working in MDPs and how they would apply in contrast to lawyer ethics rules. The Other Disciplines Group would consider how lawyers and other disciplines might work (or not work) in a MDP. The Effect on Small/Solo Law Firms will explore how MDPs may hurt or help small and solo firms if MDPs were permitted in Virginia. Education and Communication will deal with informing the rest of the bar and public on the work of the Commission and recommend ways to obtain comment and input from the bar and public on MDPs.

The Commission's meeting dates are on Tuesdays: August 29, September 26, October 24, November 28, December 19, and January 23, 2001.

Possible Objectives of the Virginia Joint Commission on MDPs

  • Inform our members about the issues - presentations, articles in The Virginia Lawyer Register, Virginia Lawyers' Weekly, VBA Journal and The Virginia Lawyer.

  • Seek input from our members - a written survey could be mailed to all VBA & VSB members; specific requests for comments issued to all committees and sections of the VBA & VSB, all local and specialty bars and other legal organizations statewide; focus groups may be conducted in various locations around the state.

  • Seek input from users of legal services - focus groups in conjunction with the Chamber of Commerce; solicitation of comments from relevant organizations; possibly a client survey.

  • Seek input from other interested professions--e.g. accountants, financial planners, etc. - Discussions with representatives of other professions and professional societies within the state; possible exploration of discussions with regulatory boards for other licensed professionals.

  • Review of Rules - review the Virginia Rules of Professional Conduct and other rules governing the practice of law in Virginia to identify rules that would be affected by MDP and consider what kinds of amendments would be necessary; consider feasibility and alternatives.

  • Make recommendations to our governing bodies

  • Advise our delegates to the ABA House of Delegates

  • Inform the Virginia Supreme Court of our work and our recommendations

To facilitate the flow of information and comments between the Joint Commission and members of the Virginia bar, the Commission should establish a webpage that can be accessed through the VSB website at www.vsb.org. The ABA Commission also has a website with links to the Commission's report and recommendations as well as many state, local and international bar associations' reports, at www.abanet.org.

 

Summary of the Report and Recommendations of the ABA Commission on MDP

In August 1999, the Commission on Multidisciplinary Practice of the American Bar Association submitted a report to the ABA on whether to make changes to the ABA Model Rules of Professional Conduct to permit lawyers to deliver legal services in professional services firms that include nonlawyers who provide nonlegal services. This form of law practice is known as multidisciplinary practice (MDP). After considerable study and testimony, the Commission concluded that there is strong interest among both clients and lawyers in allowing lawyers to practice law in MDPs.

The chief obstacle to MDPs is that most state legal ethics rules prevent lawyers from sharing legal fees with nonlawyers, entering into partnerships with nonlawyers that include the practice of law, and practicing law in a firm in which a nonlawyer owns a financial interest. The key ethics rule is Rule 5.4, but others are implicated in the discussion. The ABA Model Rules are not binding on the states, but modifications to them carry significant weight because of the leadership role of the ABA and because most states have adopted and follow a version of the Model Rules.

The impetus behind MDPs is that in recent years Big 5 accounting firms have been hiring lawyers to provide legal services to accounting clients, in part to meet competition in international markets, where lawyers are permitted to practice in MDPs. MDPs would not, however, be limited to accounting firms that offer legal services. The variety of MDPs is limited only by the potential combinations of professions involved, individuals or entities associated, and duration of the MDP, among other characteristics.

The Commission concluded that the demand for MDPs can be satisfied without impairing the legal profession's "core values" of independent judgment, confidentiality, and loyalty to the client. Therefore, the Commission recommended changes to the Model Rules to allow MDPs to exist and operate under certain restrictions and limitations, including the following:

  • Professional Independence of Judgment: If charged by a bar with a legal ethics violation, it is no defense that an MDP lawyer relied on an MDP nonlawyer's "resolution of a question of professional duty." MDPs controlled by nonlawyers must file "written undertakings" with the highest lawyer regulatory body in the state or other jurisdiction promising that they will not interfere with the lawyer's exercise of independent professional judgment and will establish and enforce procedures to that effect.

  • Confidentiality: MDP lawyers should make reasonable efforts to ensure that MDP nonlawyers working with them on legal matters act in a manner consistent with the lawyer's obligation of confidentiality to the client. In addition, MDP lawyers should prevent disclosure of confidential information to members of the MDP who are not involved with providing legal services to the client.

  • Attorney-Client Privilege: MDP lawyers must inform clients about (a) the lawyer's function as a provider of legal services in the MDP and (b) the likelihood that a client's communications to nonlawyers in the MDP on subjects unrelated to legal services would not be protected by attorney-client privilege.

  • Conflicts of Interest: For purposes of conflicts of interest, even MDP clients that receive nonlegal services are treated as clients of all MDP lawyers.

  • Holding Out as a Lawyer: MDP lawyers who are held out as lawyers (e.g., use of terms "esquire," "J.D.") are bound by the rules of professional conduct, and it is misrepresentation for MDP lawyers to describe, as nonlegal services, services traditionally performed by lawyers.

  • Pro Bono Publico Legal Service: As part of the certification process discussed below, MDPs must acknowledge the special responsibility of MDP lawyers to render pro bono publico legal services.

  • Legal Fees and Client Trust Accounts: In addition to complying with all financial recordkeeping rules of the jurisdiction, MDP lawyers must clearly designate, distinct from funds received for nonlegal services, payment for legal services and funds received on behalf of a legal services client.

  • Certification and Discipline: MDPs not controlled by lawyers are subject to an annual certification process obligating them to establish and maintain procedures protecting the independence of professional judgment of MDP lawyers, as well as an administrative audit paid for by an annual MDP certification fee and sanctions for noncompliance including withdrawal of permission to provide legal services.

Please observe that the Commission recommended keeping the current ethical rules against fee-sharing with nonlawyers, partnerships with nonlawyers offering legal services, and nonlawyer ownership interests in law firms, and the suggested amendments would create certain exceptions to permit lawyers to practice in MDPs. The Commission considered but decided not to address its recommended amendments in the "larger context of the practice of law across state borders." The Commission also stressed that it did not recommend permitting nonlawyers to deliver legal services or otherwise changing rules against unauthorized practice of law, except to allow lawyers to deliver legal services through MDPs.

 

Principal Arguments In Favor of the ABA Recommendation

Technology, instant communications, and globalization of commerce demand new ways to address and solve business problems. Clients increasingly need coordinated advice from teams of professionals from various disciplines. Clients prefer to get all these services under one roof -- "one stop shopping for a seamless web of professional services." Clients should not be precluded from getting services in this way by rules drafted by lawyers at a different time under different circumstances. Let the marketplace decide whether this is a good idea.

MDP already exists in accounting firms and other settings, denoted as "professional" or "consulting" services. It will continue to happen no matter what the legal profession wants. Get with it or get buried by it. If we want to help shape the direction this takes, we must move in this direction now before it is too late. Look at what the accounting firms are doing abroad -- acquiring law firms at a breathtaking pace. Even in the U.S., accounting firms are hiring good lawyers away from firms and good law students. These lawyers are not all "practicing tax." They are practicing law in various settings even though they say they are not. Ernst & Young is financing a law firm in Washington D.C [McKee, Nelson, Ernst & Young].

The ABA proposal is a reasonable step in the direction of bringing back under our rules those lawyers now operating outside the rules in these other settings. The proposal was supported by such diverse groups as AARP, the solo and small firm section of the ABA and the American Corporate Counsel Association. In other words, it is not just the accounting firms who are driving this. Consumer groups also testified in favor.
Core values of the legal profession -- independence of professional judgment, confidentiality, loyalty, and competence are protected by the proposal. We have other examples of lawyers working under the "control" of non-lawyers -- e.g. in-house counsel, insurance defense counsel and legal aid lawyers -- who maintain the core values.

Finally, lawyers need to face the fact that they are not well regarded by large segments of the public -- many of whom think greed and self-interest are the primary motivations of most lawyers. After the House of Delegates rejected MDPs in July 2000, an article appeared in the Wall Street Journal, criticizing the ABA's move as "anti-competitive" and "turf-protective." The rules against fee-sharing and against partnerships with non-lawyers are merely another example of lawyers trying to protect their own self-interest. If we insist on enforcing those rules, we just reinforce those negative views about the profession. Furthermore, those rules weren't even part of our ethical rules until 1928, didn't become mandatory until 1969 and were criticized as far back as the Kutak report in 1983. Thus, it is hard to argue that those rules are fundamental to our core values.

The experience in Europe seems to show that MDPs have operated for a number of years now with little or no complaint by clients.

Moreover, the cost of enforcing the ethics and UPL rules against MDPs and lawyers practicing in them may outweigh any benefits of enforcement. The definition of the "practice of law" is too broad and distinguishing between "legal information" as opposed to "legal advice" may make UPL enforcement extremely difficult. The bar could conceivably win in a court case or bar proceeding, only to face legislative intervention, thus "winning the battle, but losing the war." The market and political forces are too strong for the bar to preserve the status quo and the choice is to change voluntarily, or the legal profession will be forced involuntarily to change.


Principal Arguments Against MDPs

The ABA Commission on Multidisciplinary Practice issued an updated report in December 1999, to address some of the criticisms that have been voiced by opponents to its recommendation, including the following.
There is no empirical evidence of a need for legal services to be rendered through MDPs. The Commission essentially takes the position that it is difficult if not impossible to gather empirical data regarding the benefits of something that does not exist, and thus, concludes that the marketplace will reveal the need in due course.
Amending the rules prohibiting fee-sharing and forming partnerships with non-lawyers may give rise to unforeseen ethical problems.

Maintaining the prohibition against passive or equity investment in law firms may place traditional law firms at a competitive disadvantage in an MDP climate, because the MDPs will be able to draw on their earnings to finance and subsidize their legal services units, while traditional law firms must continue to rely on bank financing to raise capital.

The ABA recommendation does not adequately address the segregation of fees from client funds. The Commission on IOLTA (interest on lawyers' trust accounts) proposes that the existing rules of professional conduct governing a lawyer's receipt, safeguarding and distribution of client funds be made applicable to all client funds received by an MDP.

The ABA Commission's recommendation does not adequately outline how MDPs would be regulated, certified and audited in the various jurisdictions, or how these operations will be funded. The ABA Commission's recommendation does not propose adequate safeguards for the independent professional judgment of a lawyer practicing in an MDP. The infinite variety of MDP structures that may arise may call for variable rules, depending on the size of the MDP or of its legal services unit, or depending on whether the organization or the legal services unit is controlled/managed by lawyers or nonlawyers. Does the advent of MDP call for a new, more specific or broader definition for the term, "the practice of law?" The ABA report includes a new definition -- is that definition appropriate? Should the control of an MDP be limited to lawyers as a way of ensuring the independent professional judgment of lawyers practicing in MDPs? If that requirement were imposed, it would eliminate the need to treat MDPs controlled by nonlawyers differently from MDPs controlled by lawyers. Presumably, it would also eliminate the interest of the large accounting firms in having MDPs including lawyers.

Should MDPs be permitted to provide both audit and legal services to the same client? How can such conflict of interest issues be regulated? If both audit and legal services cannot be provided to the same client, is there a market for accounting/legal MDPs?

 

Other Criticisms

The focus should be on the public interest - will MDPs preserve and maintain the important core values/protections the ethical rules of the legal profession have afforded to our clients/the public? Confidentiality, loyalty, independence of judgment are important and vital principles which must be respected and enforced. Core values would be most greatly threatened in MDPs controlled by nonlawyers. The ABA proposal for court certification and audits cannot be an adequate safeguard to that patent danger. Ironically, CPA firms are required to be controlled by CPA's, but an MDP whose activities might be 99% the practice of law can be controlled by nonlawyers.

The ABA offers no empirical evidence that the consumers of legal services are demanding MDPs, nor really any benefit analysis at all. The Big 5 accounting firms are the impetus for and champions of MDPs, but their motive is advancement of their own economic interests. The ABA's proposed safeguards to the core values of the legal profession, resting in the hands of the already over-burdened and underfunded state supreme courts, are not likely to be effective. Enforcement is likely to be quite inconsistent from one jurisdiction to the next. How can courts discipline nonlawyers who are not subject to the court's powers of suspension or disbarment?
Once the MDP door is open, the only limits are the bounds of the human imagination: how to preserve core values of the legal profession in an MDP consisting of a tow truck operator, an ambulance driver, an emergency room doctor, a chiropractor and a personal injury lawyer?

Burying our heads in the sand is not an option. Opposition to MDPs by the organized bar will not stem the tide of de facto MDP's in the accounting firms and elsewhere. The existing rules must be aggressively enforced to retard the growth of MDPs, or lawyers will be put to an increasing competitive disadvantage compared to accountants and others who provide legal services without being required to adhere to the same ethical standards that govern lawyers.

Small practitioners, solos and young lawyers starting out in practice will be most adversely affected by MDPs, as they will not be able to compete with large well-funded accounting firms. Young lawyers will suffer from the lack of mentoring by experienced, ethical lawyers as they learn how to practice in the real world. The ultimate victims will be the public, who will lose the right to choose and the right to the personal services of a trusted lawyer.

A lawyer in an MDP would need to have the information necessary to identify conflicts of interest and address them; this process will be more complicated in an MDP, especially where clients may receive multiple services from the MDP, and only come to request legal services at a later stage of the relationship. It is inevitable that the sharing of fees earned through blended professional services will affect the lawyers' judgment for the good of the organization rather than the singular benefit to the client. Lawyer advertising has demeaned our profession. Advertising, solicitation and referral issues in other professions are not subject to the same degree of standards and regulation. It can only get worse with MDP.

Consumers already do not understand the benefits they derive from the core values of our profession. How will lawyers go about explaining the loss of those benefits to a client who engages an MDP?

Will there be any restrictions on who can form MDPs? Will an attorney be allowed to form a MDP with a doctor and a chiropractor and share in the fees generated by a personal injury client? What will prevent the attorney asking for or the doctor recommending a course of treatment which may be unnecessary because the fees generated will benefit the MDP? Can the doctor in the MDP properly serve as an expert witness in a case when a positive outcome will financially benefit the MDP and ultimately the doctor and attorney personally? Is it enough to state that the alliance can affect the credibility of the expert witness and to let the jury decide? Can personal injury lawyers form MDPs with tow truck and ambulance drivers and circumvent the rules against "running and capping?" Will an estate attorney be allowed to form a MDP with a tax planner, certified financial planner and bank, which is consistent with "one stop shopping" but could lead to the bilking of the client for fees?

Will multi-state practice of law be permitted? Large MDPs will cross state boundaries and will form national practice groups. What will prevent the multi-state practice of law under the banner of the MDP? The MDPs can grow into a huge number and the attorneys operating under a MDP banner may not even be licensed to practice in the jurisdiction where services are rendered. Will the result be the end to the organized bars and licensing? How will the bars enforce restrictions on foreign attorney practice?

What will happens to pro bono legal services when lawyers are working for nonlawyer owners? Will nonlawyers care about the unmet legal needs of those who cannot afford to pay for legal services and allow lawyers in MDPs to fulfill their commitment to pro bono? Insurance defense attorneys have already seen the erosion of client protection caused by nonlawyer auditing of legal bills and supervision of litigation. Nonlawyers commonly do not appreciate the importance of, and the reasons for, rules governing lawyer conduct such as confidentiality, conflicts of interest and independence of professional judgment. It is unlikely that the supreme courts of the various states, already strapped trying to regulate the legal profession, can meaningfully audit and regulate MDPs. The American Institute of Certified Public Accountants has voiced its strong support for the MDP model, while strongly criticizing any proposal that would attempt to regulate MDPs to ensure that our Rules of Professional Conduct are followed. The utility of this proposal is no more than a means for accountants to take over the legal profession. The growth of MDPs as a mode of providing professional services would erode the value of lawyers in American law and society, and would possibly threaten the fundamental rights of litigants, such as the right to a civil jury trial.



 

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