To The Commission's Report

I have been following the public hearings and also have extensive insight in this issue because of my own involvement in the CPA regulatory world as a lawyer (the flip side of the MDP concern).

I knew that the ABA would bend to the powers, greater than itself, but I thought the ABA would suggest more safeguards to protect the public. Do you relaize how few times the principle of "protecting the public" is espoused within the report?

May I suggest that a "possible annual audit" from the highest judicial body in the state is INSUFFICIENT to counter any harm to the public and a greater erosion of the lawyer's professional image in the community.

May I suggest that ALL ENGAGEMENT LETTERS OF AN MDP be reviewed by the State Bar in that state to ensure , BEFORE the MDP deals with the public, that all DISCLOSURES are present. Specifically, I would suggest that the following disclosure be more prominent than any other:

IMPORTANT NOTE: TO THE EXTENT THAT YOU ENGAGE THE SERVICES OF OUR FIRM , ABC LLC, WHICH IS MULTI-DISCIPLINARY IN PRACTICE AND EMPLOYS LAWYERS AND NON-LAWYERS, PLEASE BE ADVISED THAT ANY LEGAL SERVICES PROVIDED MAY NOT ENJOY THE CONFIDENTIALITY PROVISIONS AFFORDED TO YOU BY A FIRM OF SOLELY LAWYERS. Example : if 1 of our non-lawyer employees were to leave the firm, or if a non-lawyer were deposed about your private matters, such a person could not claim confidentiality on your behalf.

There are other problems but the confidentiality issue is the one that MOST imperils the consumer of legal services.

I hope this comment can be considered by the House of Delegates. Thank you.

Silvia Ibanez, CPA,JD,CFP