October 05, 2011

Damian Gisbert - Center for Professional Responsibility

May 12, 1999

Mr. Sherwin Simmons
ABA Commission on Multidisciplinary Practice
541 North Fairbanks Court
Chicago, IL 60611

Dear Chairman Simmons;

I am the Financial Director of Kellogg’s Espana, S.A. headquartered in Battle Creek, Michigan U.S.A. We are part of Kellogg’s Worldwide. As a satisfied customer of multidisciplinary service firms, we thought it would be important to share our experiences with the Commission and make recommendations whether existing regulations should be changed to permit partnerships between lawyers and other professionals.

We have retained MDPs on several occasions to provide advice on legal, business and financial matters and have their integrated services to be extremely useful for several reasons. First, we have an expanding global presence, which is constantly expanding as a result of electronic communications and instant information. We have turned to MDPs because they have a global perspective and are already conversant in the law and customs of the international marketplace. Second, we have found that many of our decisions in this complex environment require the intersection of law and business. MDPs can approach corporate decision-making with an interdisciplinary team of professionals who can analyze the various aspects of a solution. Finally, MDPs offer a unique package of integrated advice. Advice from lawyers tends to be limited and does not focus on strategic matters. Similarly, tax advisors and financial consultants lack necessary training and expertise to advise on legal issues. We have experienced the synergy from different specialists working together to provide rich analysis and sound advice.

I hope our perspective is useful as you consider this important issue. Thank you for allowing us to provide our comments to the Commission.

Very truly yours,

Damian Gisbert