II. Opinion Practice Management: Committees
A. Existence and Number of Committees
3. How many opinion committees does your firm have? (Please check only one.)
- None
|
70
|
23%
|
- One
|
199
|
65%
|
- More Than One
|
38
|
12%
|
Total
|
307
|
|
3.1 How is responsibility allocated among your firm’s various opinion committees? (Please check all that apply.)
- By practice group or area of law
|
28
|
76%
|
- By geography (e.g., by office location)
|
9
|
24%
|
- By function (e.g., one committee (or its members)
approves opinion policies and another (or its members)
reviews Opinion Letters to be provided by your firm)
|
7
|
19%
|
- Other (Please describe.)
|
7
|
19%
|
Total
|
37
|
|
B. Committee Functions
(1) Reviewing, Clearing, or Approving Opinion Letters
4. Does/do your firm’s opinion committee(s) (including action by committee members) review, clear, or approve individual Opinion Letters to be provided by your firm?
- Yes
|
192
|
81%
|
- No
|
46
|
19%
|
Total
|
238
|
|
4.1 Which of the following better describes what your firm’s opinion committee or committees do (or what members do on behalf of the committee or committees)? (Please check only one answer.)
- Review, clear, or approve all or substantially all Opinion Letters
|
144
|
77%
|
- Review, clear, or approve some (but not all or substantially all) Opinion Letters
|
44
|
23%
|
Total
|
188
|
|
4.1.1 Which of the following act for your firm’s opinion committee or committees in taking this action? (Please check all that apply.)
- The full committee
|
14
|
10%
|
- One or more subcommittees
|
2
|
1%
|
- Any committee member
|
97
|
68%
|
- The committee chair
|
13
|
9%
|
- A designated committee member (other than the chair)
|
9
|
6%
|
- Two or more committee members, acting together
|
24
|
17%
|
- Other (Please describe.)
|
19
|
13%
|
Total
|
143
|
|
4.1.2 Which of the following act for your firm’s opinion committee or committees in taking this action? (Please check all that apply.)
- The full committee
|
7
|
16%
|
- One or more subcommittees
|
5
|
11%
|
- Any committee member
|
34
|
77%
|
- The committee chair
|
11
|
25%
|
- A designated committee member (other than the chair)
|
6
|
14%
|
- Two or more committee members, acting together
|
2
|
5%
|
- Other (Please describe.)
|
2
|
5%
|
Total
|
44
|
|
4.1.3 Opinion Letters that are reviewed, cleared, or approved typically relate to which of the following practice areas? (Please check all that apply.)
- Public securities offerings (debt or equity)
|
22
|
50%
|
- Private securities offerings (debt or equity including, e.g., private equity & venture capital)
|
25
|
57%
|
- Lending
|
38
|
82%
|
- Securitizations
|
19
|
43%
|
- Substantive consolidation or true sales
|
19
|
43%
|
- Mergers and acquisitions
|
23
|
52%
|
- Other (Please describe.)
|
7
|
16%
|
Total
|
44
|
|
(2) Preparing or Approving Firm Policies and Procedures
5. Does/do your firm’s opinion committee(s) (including actions by committee members) prepare or approve firm opinion policies or procedures?
- Yes
|
201
|
86%
|
- No
|
33
|
14%
|
Total
|
234
|
|
5.1 Which of the following act for your firm’s opinion committee or committees in taking this action? (Please check all that apply.)
- The full committee
|
115
|
59%
|
- One or more subcommittees
|
17
|
9%
|
- Any committee member
|
39
|
20%
|
- The committee chair
|
48
|
25%
|
- A designated committee member (other than the chair)
|
15
|
8%
|
- Two or more committee members, acting together
|
27
|
14%
|
- Other (Please describe.)
|
9
|
5%
|
Total
|
195
|
|
5.2 Which of the following best describes your firm’s practices in taking this action?
- Your firm’s opinion committee(s) usually obtains the approval of or consults with another person or group in taking this action
|
90
|
47%
|
- Your firm’s opinion committee(s) usually does not obtain the approval of or consult with another person or group in taking this action
|
73
|
38%
|
- It depends (Please explain.)
|
30
|
16%
|
Total
|
193
|
|
5.2.1 Who consults or approves? (Please check all that apply.)
- The firm’s general counsel
|
42
|
35%
|
- One or more designated members of a designated practice group or groups
|
46
|
39%
|
- Any partner (or equivalent) of a designated practice group or groups
|
29
|
24%
|
- The firm’s management committee
|
30
|
25%
|
- The firm’s managing partner
|
20
|
17%
|
- It depends (Please explain.)
|
18
|
15%
|
Total
|
119
|
|
5.3 As a general matter, do firm opinion policies or procedures relating to preparation or approval of Opinion Letters by the opinion committee or committees relate to Opinion Letters covered by this survey delivered by all of your firm’s practice groups?
- Yes
|
161
|
83%
|
- No (Please list practice groups that deliver Opinion Letters of the types covered by this survey that are not dealt with by your firm’s opinion committee or committees.)
|
33
|
17%
|
Total
|
194
|
|
5.4 As a general matter, do firm opinion policies or procedures relating to preparation or approval of Opinion Letters by the opinion committee or committees relate to Opinion Letters covered by this survey delivered by all of your firm’s offices?
- Yes
|
175
|
90%
|
- No (Please list offices that deliver Opinion Letters of the types covered by this survey that are not dealt with by your firm’s opinion committee or committees.)
|
20
|
10%
|
Total
|
195
|
|
(3) Administering, Monitoring, or Waiving Compliance with Policies or Procedures
6. Does/do your firm’s opinion committee(s) (including actions by committee members) administer, monitor, or waive compliance with firm opinion policies or procedures?
- Yes
|
183
|
79%
|
- No
|
48
|
21%
|
Total
|
231
|
|
6.1 Which of the following act for your firm’s opinion committee or committees in taking this action? (Please check all that apply.)
- The full committee
|
46
|
26%
|
- One or more subcommittees
|
10
|
6%
|
- Any committee member
|
86
|
48%
|
- The committee chair
|
56
|
31%
|
- A designated committee member (other than the chair)
|
13
|
7%
|
- Two or more committee members, acting together
|
43
|
26%
|
- Other (Please describe.)
|
16
|
9%
|
Total
|
178
|
|
6.2 Which of the following best describes your firm’s practices in taking this action?
- Your firm’s opinion committee(s) usually obtains the approval of or consults with another person or group in taking this action
|
66
|
38%
|
- Your firm’s opinion committee(s) usually does not obtain the approval of or consult with another person or group in taking this action
|
86
|
49%
|
- It depends (Please explain.)
|
23
|
13%
|
Total
|
175
|
|
6.2.1 Who consults or approves? (Please check all that apply.)
- The firm’s general counsel
|
32
|
36%
|
- One or more designated members of a designated practice group or groups
|
40
|
46%
|
- Any partner (or equivalent) of a designated practice group or groups
|
28
|
32%
|
- The firm’s management committee
|
9
|
10%
|
- The firm’s managing partner
|
11
|
13%
|
- It depends (Please explain.)
|
15
|
17%
|
Total
|
|
88
|
6.3 As a general matter, do firm opinion policies or procedures relating to administering, monitoring, or waiving compliance by the opinion committee or committees relate to Opinion Letters covered by this survey delivered by all of your firm’s practice groups?
- Yes
|
151
|
86%
|
- No (Please list practice groups that deliver Opinion Letters of the types covered by this survey that are not dealt with by your firm’s opinion committee or committees.)
|
25
|
14%
|
Total
|
176
|
|
6.4 As a general matter, do firm opinion policies or procedures relating to administering, monitoring, or waiving compliance by the opinion committee or committees relate to Opinion Letters of the types covered by this survey that are delivered by all of your firm’s offices?
- Yes
|
150
|
91%
|
- No (Please list offices that deliver Opinion Letters of the types covered by this survey that are not dealt with by your firm’s opinion committee or committees.)
|
15
|
9%
|
Total
|
165
|
|
(4) Preparing or Approving Form, Sample, or Model Opinions, Opinion Letters, Supporting Documentation, or Other Materials
7. Does/do your firm’s opinion committee(s) (including actions by committee members) prepare or approve forms, samples, or model Opinions, Opinion Letters, supporting documentation, or other materials?
- Yes
|
186
|
82%
|
- No
|
41
|
18%
|
Total
|
227
|
|
7.1 Which of the following act for your firm’s opinion committee or committees in taking this action? (Please check all that apply.)
- The full committee
|
90
|
50%
|
- One or more subcommittees
|
26
|
14%
|
- Any committee member
|
44
|
24%
|
- The committee chair
|
55
|
30%
|
- A designated committee member (other than the chair)
|
22
|
12%
|
- Two or more committee members, acting together
|
34
|
19%
|
- Other (Please describe.)
|
8
|
4%
|
Total
|
182
|
|
7.2 Which of the following best describes your firm’s practices in taking this action?
- Your firm’s opinion committee(s) usually obtains the approval of or consults with another person or group in taking this action
|
61
|
34%
|
- Your firm’s opinion committee(s) usually does not obtain the approval of or consult with another person or group in taking this action
|
109
|
60%
|
- It depends (Please explain.)
|
12
|
7%
|
Total
|
182
|
|
7.2.1 Who consults or approves? (Please check all that apply.)
- The firm’s general counsel
|
22
|
30%
|
- One or more designated members of a designated practice group or groups
|
43
|
59%
|
- Any partner (or equivalent) of a designated practice group or groups
|
22
|
30%
|
- The firm’s management committee
|
8
|
11%
|
- The firm’s managing partner
|
10
|
14%
|
- It depends (Please explain.)
|
12
|
16%
|
Total
|
73
|
|
(5) Conducting or Overseeing Education or Training of Lawyers on Opinion Matters
8. Does/do your firm’s opinion committee(s) (including actions by committee members) conduct or oversee education or training of your firm’s lawyers on opinion matters?
- Yes
|
168
|
75%
|
- No
|
57
|
25%
|
Total
|
225
|
|
(6) Other Committee Functions
9. Does/do your firm’s opinion committee(s) (including actions by committee members) perform any other functions not covered by earlier questions?
- Yes
|
37
|
16%
|
- No
|
188
|
84%
|
Total
|
225
|
|
C. Committee Membership
10. How are members of your firm’s opinion committee or committees appointed? (Please check all that apply.)
- By firm management or management committee
|
145
|
64%
|
- By firm general counsel
|
12
|
5%
|
- By practice groups
|
42
|
19%
|
- By opinion committee chair
|
50
|
22%
|
- By the committee itself
|
42
|
19%
|
- It depends on the committee (Please explain.)
|
6
|
3%
|
- Other (Please describe.)
|
14
|
6%
|
Total
|
226
|
|
11. Is each committee member typically a partner (or equivalent) in your firm?
- Yes
|
179
|
80%
|
- Yes, with limited exceptions (Please describe.)
|
40
|
18%
|
- No (Please describe who else can be a committee member.)
|
5
|
2%
|
Total
|
224
|
|
12. Is each committee member typically a business lawyer?
- Yes
|
165
|
74%
|
- Yes, with limited exceptions (Please explain.)
|
36
|
16%
|
- No
|
22
|
10%
|
Total
|
223
|
|
13. Do any of your firm’s opinion committees currently have as a member: (Please check all that apply.)
- A litigator
|
55
|
26%
|
- A bankruptcy lawyer
|
74
|
34%
|
- A tax lawyer
|
88
|
41%
|
- An IP lawyer
|
25
|
12%
|
- A real estate lawyer
|
152
|
70%
|
- A lawyer expert in opinion practice
|
165
|
76%
|
- A representative of one or more designated practice groups
|
99
|
46%
|
- Your firm’s general counsel
|
45
|
21%
|
- A representative of the firm’s client intake committee
|
9
|
4%
|
- Another person from firm management (Please identify.)
|
19
|
9%
|
Total
|
216
|
|
III. Firm Opinion Practice Management: Consultation
14. Does your firm have a policy or practice regarding Opinion Preparers consulting with or obtaining approval by another lawyer or lawyers (the “Consulted Lawyer”) before providing an Opinion Letter? (Note: The Consulted Lawyer could be a firm opinion committee(s) or one or more members thereof.)
- Yes
|
245
|
83%
|
- No
|
49
|
17%
|
Total
|
294
|
|
15. As a general matter, which of the following best describes your firm’s policy or practice regarding consultation or approval?
Consultation or approval is called for:
|
- Usually, with some exceptions
|
90
|
37%
|
- Only in particular cases
|
30
|
12%
|
- Always
|
122
|
50%
|
Total
|
242
|
|
16. As a general matter, does your firm’s policy or practice regarding consultation or approval apply to all of your firm’s practice groups and offices that give Opinions of types covered by this survey?
- Yes
|
219
|
91%
|
- No (Please explain.)
|
23
|
10%
|
Total
|
242
|
|
17. Do the details of the policy or practice vary from practice group to practice group, or from office to office?
- Yes (Please explain.)
|
53
|
22%
|
- No
|
187
|
78%
|
Total
|
240
|
|
18. Which of the following best describes your firm’s policy or practice regarding consultation or approval? (Please check only one box.)
- (a1) Opinion Preparers are required or expected to consult or seek approval regarding all or substantially all Opinion Letters
|
188
|
78%
|
- (a2) Opinion Preparers are required or expected to consult or seek approval regarding some (but not substantially all) Opinion Letters
|
24
|
10%
|
- (b1) Opinion Preparers are encouraged (but not required or expected) to consult or seek approval regarding all or substantially all Opinion Letters
|
18
|
7%
|
- (b2) Opinion Preparers are encouraged (but not required or expected) to consult or seek approval regarding some (but not substantially all) Opinion Letters
|
12
|
5%
|
Total
|
242
|
|
18.1 In what situations is consultation or approval called for? (Please check all numbered items that apply.)
- The Opinion Letter or particular Opinions are significantly different from your firm’s form, sample, or model
|
20
|
83%
|
- Delivering the Opinion Letter poses unusual risks because of the size of the transaction
|
15
|
63%
|
- Delivering the Opinion Letter poses unusual risks because of the nature of the transaction
|
17
|
74%
|
- The Opinion Letter presents issues that are not straightforward, not easily resolved, or not previously addressed by your firm
|
18
|
75%
|
- Only one partner or equivalent is working on the transaction
|
6
|
25%
|
- The Opinion Letter is not routine (For example, it is not a type your firm often provides or is not being given as a repeat Opinion Letter in a series of closings in the same transaction for the same client.)
|
18
|
75%
|
- The Opinion Letter covers a matter requiring expertise not possessed by Opinion Preparers (For example, the Uniform Commercial Code, the federal securities laws, or the law of a particular state.)
|
20
|
83%
|
- Other (Please explain.)
|
0
|
0%
|
- Your firm’s policies are not specific (Please explain.)
|
1
|
4%
|
- Total
|
24
|
|
18.2 In what situations is consultation or approval called for? (Please check all numbered items that apply.)
- The Opinion Letter or particular Opinions are significantly different from your firm’s form, sample, or model
|
9
|
75%
|
- Delivering the Opinion Letter poses unusual risks because of the size of the transaction
|
5
|
42%
|
- Delivering the Opinion Letter poses unusual risks because of the nature of the transaction
|
7
|
58%
|
- The Opinion Letter presents issues that are not straightforward, not easily resolved, or not previously addressed by your firm
|
10
|
83%
|
- Only one partner or equivalent is working on the transaction
|
1
|
8%
|
- The Opinion Letter is not routine (For example, it is not a type your firm often provides or is not being given as a repeat Opinion Letter in a series of closings in the same transaction for the same client.)
|
11
|
92%
|
- The Opinion Letter covers a matter requiring expertise not possessed by Opinion Preparers (For example, the Uniform Commercial Code, the federal securities laws, or the law of a particular state.)
|
9
|
75%
|
- Other (Please explain.)
|
1
|
8%
|
- Your firm’s policies are not specific (Please explain.)
|
1
|
8%
|
- Total
|
12
|
|
19. Which of the following best describes your firm’s practice regarding exceptions to your firm’s policy or practice requiring or expecting consultation?
- Exceptions are never made
|
80
|
36%
|
- Exceptions are rarely made
|
124
|
55%
|
- Exceptions are often made
|
21
|
9%
|
Total
|
225
|
|
19.1. Who can approve an exception? (Please check all that apply.)
- An Opinion Preparer
|
20
|
14%
|
- The Consulted Lawyer (Defined as another lawyer who, under your firm’s policy or practice, consults with Opinion Preparers about or approves an Opinion Letter or an Opinion before an Opinion Letter is delivered.)
|
42
|
29%
|
- An opinion committee
|
61
|
42%
|
- The chair or another member or members of an opinion committee
|
66
|
46%
|
- A lawyer or lawyers designated or approved by an opinion committee or committee member(s)
|
13
|
9%
|
- A lawyer or lawyers having position(s) in management of your firm or relationships with a relevant client or clients
|
23
|
16%
|
- A lawyer or lawyers in one or more designated practice groups or with special expertise
|
28
|
19%
|
- A lawyer or lawyers designated in some other way (Please explain.)
|
2
|
1%
|
- Your firm’s general counsel
|
24
|
17%
|
- Depends on the situation (Please explain.)
|
6
|
4%
|
Total
|
145
|
|
20. Does your firm’s policy or practice regarding consultation call for the Consulted Lawyer not to be otherwise involved in the transaction?
- Always
|
67
|
28%
|
- In some but not all situations (Please explain.)
|
29
|
12%
|
- No
|
145
|
60%
|
- Total
|
241
|
|
21. Does your firm’s policy or practice regarding consultation call for the Consulted Lawyer not to be otherwise involved with the client?
- Always
|
10
|
4%
|
- In some but not all situations (Please explain.)
|
24
|
10%
|
- No
|
203
|
86%
|
- Total
|
237
|
|
22. Who can the Consulted Lawyer be? (Please check all that apply.)
1. An entire opinion committee
|
55
|
23%
|
2. Any member of an opinion committee
|
152
|
64%
|
3. A designated member or members or other designee of an opinion committee
|
64
|
27%
|
4. Any lawyer in your firm
|
8
|
3%
|
5. Any partner or equivalent in your firm
|
84
|
35%
|
6. A lawyer or lawyers with expertise in at least one of the legal areas addressed in the Opinion Letter
|
100
|
41%
|
7. A lawyer or lawyers with expertise in at least one type of transaction that is the subject of an Opinion in the Opinion Letter
|
57
|
24%
|
8. Both a committee or a member(s) or designee(s) of a committee and a lawyer with such expertise
|
56
|
23%
|
9. A lawyer from a list of designated lawyers who may serve as a Consulted Lawyer
|
19
|
8%
|
10. A lawyer in one or more designated practice groups
|
12
|
5%
|
11. Your firm’s general counsel
|
22
|
9%
|
12. Other (Please describe.)
|
20
|
8%
|
Total
|
239
|
|
22.1 Who prepares the list of designated lawyers who may serve as the Consulted Lawyer? (Please check all that apply.)
- An opinion committee or a member or members of an opinion committee
|
9
|
50%
|
- One or more practice groups (or a member or members of a practice group(s) responsible for or expert in all or a portion of the transaction
|
3
|
17%
|
- Firm management or your firm’s general counsel
|
8
|
44%
|
- A combination of the foregoing (Please describe.)
|
3
|
17%
|
- Other (Please describe.)
|
2
|
11%
|
Total
|
18
|
|
22.2 Do the Opinion Preparers have discretion to select which member of an opinion committee will be the Consulted Lawyer?
- Yes
|
138
|
94%
|
- No (Please indicate who makes the selection.)
|
9
|
6%
|
Total
|
147
|
|
22.3 Do the Opinion Preparers have discretion to select which designated member or members or other designee of an opinion committee will be the Consulted Lawyer?
- Yes
|
51
|
82%
|
- No (Please indicate who makes the selection.)
|
11
|
18%
|
Total
|
62
|
|
22.4 Do the Opinion Preparers have discretion to select which lawyer in your firm will be the Consulted Lawyer?
- Yes
|
8
|
100%
|
- No (Please indicate who makes the selection.)
|
0
|
0%
|
Total
|
8
|
|
22.5 Do the Opinion Preparers have discretion to select which partner or equivalent in your firm will be the Consulted Lawyer?
- Yes
|
79
|
95%
|
- No (Please indicate who makes the selection.)
|
4
|
5%
|
Total
|
83
|
|
22.6 Do the Opinion Preparers have discretion to select which lawyer or lawyers with expertise in at least one of the legal areas addressed in the Opinion Letter will be the Consulted Lawyer?
- Yes
|
84
|
87%
|
- No (Please indicate who makes the selection.)
|
13
|
13%
|
Total
|
97
|
|
22.7 Do the Opinion Preparers have discretion to select which lawyer or lawyers with expertise in at least one type of transaction that is the subject of an Opinion in the Opinion Letter will be the Consulted Lawyer?
- Yes
|
50
|
93%
|
- No (Please indicate who makes the selection.)
|
4
|
7%
|
Total
|
54
|
|
22.8 Do the Opinion Preparers have discretion to select which committee or a member(s) or designee(s) of a committee and a lawyer with such expertise will be the Consulted Lawyer?
- Yes
|
46
|
84%
|
- No (Please indicate who makes the selection.)
|
9
|
16%
|
Total
|
55
|
|
22.9 Do the Opinion Preparers have discretion to select which lawyer from a list of designated lawyers will be the Consulted Lawyer?
- Yes
|
18
|
100%
|
- No (Please indicate who makes the selection.)
|
0
|
0%
|
Total
|
18
|
|
22.10 Do the Opinion Preparers have discretion to select which lawyer in one or more designated practice groups will be the Consulted Lawyer?
- Yes
|
9
|
82%
|
- No (Please indicate who makes the selection.)
|
2
|
18%
|
Total
|
11
|
|
23. In general, does your firm’s policy or practice regarding consultation call for the Consulted Lawyer to be a partner or equivalent in your firm?
- Yes, always
|
174
|
74%
|
- Yes, with exceptions (Please describe.)
|
45
|
19%
|
- No
|
15
|
6%
|
- Total
|
234
|
|
24. Does your firm’s policy or practice address when the Consulted Lawyer is supposed to be first consulted?
- Yes
|
81
|
35%
|
- No
|
154
|
66%
|
Total
|
235
|
|
24.1 When is the Consulted Lawyer supposed to be first consulted? (Please check the one answer that best describes your firm’s policy or practice.)
- When the need for an Opinion Letter is identified
|
10
|
11%
|
- When negotiation of an agreement calling for an Opinion Letter begins
|
6
|
7%
|
- When drafting of the Opinion Letter begins
|
7
|
8%
|
- Prior to providing the draft Opinion Letter to the other side
|
45
|
50%
|
- Any time prior to delivery of the Opinion Letter
|
14
|
16%
|
- At some other time (Please describe.)
|
8
|
9%
|
Total
|
90
|
|
25. Which of the following are responsibilities of the Consulted Lawyer? (Please check all that apply.)
- Determine that the form (as distinguished from the substance) of the Opinion Letter satisfies your firm’s policy or practice
|
170
|
72%
|
- Answer questions of the Opinion Preparers
|
211
|
89%
|
- Determine whether the Opinion Letter raises special concerns
|
208
|
88%
|
- Determine whether the Opinion Letter requires special procedures (due, for example, in either case, to a legal matter addressed by the Opinion Letter, the nature, size, or type of transaction, the particular client involved, or the relationship between the Opinion Preparers and the client) (Please describe.)
|
97
|
41%
|
- Be satisfied about matters determined by the Consulted Lawyer or Opinion Preparers to require special attention
|
174
|
74%
|
- Be satisfied about the substance of matters within the Consulted Lawyer’s expertise
|
168
|
71%
|
- Identify issues on the face of the Opinion Letter (e.g., unusual wording, apparently incorrect Opinion)
|
193
|
82%
|
- “Concur” in the Opinion Letter as if the Consulted Lawyer had been an Opinion Preparer
|
68
|
29%
|
- Review backup documentation or otherwise determine that sufficient work was done to support Opinions being given
|
65
|
28%
|
- Sign off on delivery of the Opinion Letter
|
123
|
52%
|
- Other (Please describe.)
|
8
|
3%
|
- It depends on the situation (Please explain.)
|
9
|
4%
|
Total |
236 |
|
26. Does your firm have a policy or practice calling for a follow-up consultation with the Consulted Lawyer before the Opinion Letter is provided (for example to confirm that any issues previously identified have been addressed or that no new issues or problems have arisen)?
- Yes
|
68
|
29%
|
- No
|
166
|
71%
|
Total
|
234
|
|
27. Does your firm’s policy or practice call for consultation between the Consulted Lawyer and the Opinion Preparers ordinarily to be memorialized?
- Yes
|
78
|
34%
|
- No
|
155
|
67%
|
Total
|
233
|
|
27.1 How? (Please check all that apply.)
- By a notation on an internal copy of the Opinion Letter
|
42
|
54%
|
- By a memo in a firm file or archive of Opinion Letters
|
26
|
33%
|
- By a memo in the transaction file
|
21
|
27%
|
- In some other way (Please describe.)
|
20
|
26%
|
Total
|
78
|
|