MCLE Today: Let’S Talk – a Session with Clereg

MCLE Today: Let’s Talk – A Session with CLEreg

Presented By:

Dan Levering Pennsylvania CLE Board Harrisburg, PA

Karen Litscher-Johnson Board of the Supreme Court of Illinois Chicago, IL

Dawn McKnight Colorado Supreme Court Denver, CO

Andrew Ottiger Practising Law Institute New York, NY

Presented at: ACLEA 54th Annual Meeting July 28, 2018 Portland, Oregon Dan Levering Pennsylvania CLE Board Harrisburg, PA

Daniel Levering is the Administrator for the Pennsylvania Continuing Legal Education Board. He holds a Bachelor of Arts Degree in Art and Education from Bridgewater University in Massachusetts. Before joining the Pennsylvania CLE Board, he taught art at Weymouth High School in Massachusetts. He is a Past‐President of the Continuing Legal Education Regulators Association (CLEreg). Mr. Levering joined the PA CLE Board as Provider Relations Director and served as a liaison to over 150 Accredited Sponsors. He established Pennsylvania CLE's provider orientation program, helped develop Pennsylvania's Annual Provider Conferences and was extensively involved in the production and implementation of various automated processing programs. Since becoming Administrator in 2001, he has worked with the Pennsylvania CLE Board and legal community to provide lawyers with high levels of regulatory service and quality educational opportunities.

Karen Litscher-Johnson Board of the Supreme Court of Illinois Chicago, IL

Karen Litscher Johnson, Director, Illinois MCLE Board As the first Director of the MCLE Board of the Supreme Court of Illinois, Karen Litscher Johnson works under the direction of the Court and the MCLE Board to conduct the Board's operations. Her experience includes six years as National Director of Professional Development for DLA Piper where she planned and managed the firm's attorney education programs, including MCLE accreditation, for all of its U.S. offices. Before joining DLA Piper, Ms. Johnson was a Litigation Partner with a mid‐sized Chicago law firm, Much Shelist, P.C. Ms. Johnson received her Juris Doctor degree from Cornell Law School and graduated from the University of Wisconsin‐Madison. She served as Chair of the Chicago Bar Association Young Lawyers Section (YLS ). During eight years in bar leadership, she planned dozens of CLE courses and organized many public and bar service projects. Before becoming a lawyer, Ms. Johnson was a radio reporter and anchor in Madison, Wisconsin.

Dawn McKnight Colorado Supreme Court Denver, CO

Dawn McKnight is Deputy Regulation Counsel overseeing admissions, registration, and mandatory continuing legal and judicial education. Ms. McKnight received her undergraduate degree from San Francisco State University and her law degree from the University of Denver Sturm College of Law. After graduating from law school, Ms. McKnight practiced environmental law for a nonprofit, then became a civil litigation associate for a private firm. Prior to joining the Office of Attorney Regulation Counsel, Ms. McKnight was Assistant Executive Director and Publications Director of Colorado Bar Association CLE for 14 years. Ms. McKnight is a member of the National Organization of Bar Counsel; the Denver, Colorado and American Bar Associations; the Colorado Women’s Bar Association; the National Conference of Bar Examiners; and, the National Continuing Legal Education Regulators Association. She is also a Fellow of the Colorado Bar Foundation and a Circle of Minerva member of the Women’s Bar Foundation. She is the current Chair of the Board of Directors of the Legal Community Credit Union (d/b/a Options Credit Union). Ms. McKnight currently participates in the Supreme Court Advisory Committee’s Proactive Management‐Based Regulation Subcommittee.

Andrew Ottiger Practising Law Institute New York, NY

Andrew Ottiger is the Director of Accreditation and Compliance for the Practising Law Institute (PLI), a not‐for‐profit continuing legal education organization based in New York City. Andrew is responsible for the accreditation and compliance of PLI and the SEC Institute, A Division of Practising Law Institute, and all their programs in all U.S. and foreign jurisdictions that require mandatory continuing legal education. PLI and the SEC Institute produces more than 450 exclusive live CLE programs annually which are also made available online in various formats. In addition to MCLE, Andrew is responsible for the accreditation and compliance for more than a dozen other professional certifications that PLI provides continuing education for including accountants and CPAs (PLI is listed as a sponsor of CPE on the National Registry of CPE Sponsors), certified fraud examiners (CFEs), IRS enrolled agents, anti‐money laundering specialists (AML), certified compliance officers, certified privacy professionals, certified HR professionals, auditors, financial and banking professionals, Certified Financial Planners (CFPs), and more. Andrew works closely with PLI's programs and R&D departments to guide them on regulator's rules, regulations, and instructional design requirements during program and product development. Andrew is also responsible for the compliance of PLI business systems and operations related to the advertisement, calculation, issuance, and reporting of CLE and other continuing education credits. Andrew is a current Co‐Chair of ACLEA's MCLE Committee and is a frequent advisor on rules, regulations, processes, and trends in accreditation. Andrew received his B.A. in Political Science from Brooklyn College, City University of New York.

What You Need to Know About the New Illinois CLE Requirement

For the past decade, the Illinois Supreme Court has encouraged attorneys to take diversity CLE courses and mental health and substance abuse CLE courses and activities to fulfill part of their professional responsibility requirement. Over that decade, the percentages of those courses offered and taken in Illinois has remained practically unchanged.

At the same time, the Court has recognized that the profession’s challenges in the diversity arena, and in the mental health and substance abuse arena, remain daunting. To attempt to reverse the trend, the Court adopted the recommendation of the Illinois Supreme Court Commission on Professionalism that Illinois attorneys take one hour of diversity and inclusion CLE and one hour of mental health and substance abuse CLE during each two-year reporting period.

This adoption comes in light of national efforts, particularly by the American Bar Association, to encourage all states to require their lawyers to take courses in diversity and mental health and substance abuse.

Further background information is available in the Supreme Court’s press release and the Commission’s recommendation letter to the Court. What follows is some additional information for both attorneys and providers: FAQs for Attorneys 1. What is the new diversity/inclusion and mental health/substance abuse CLE requirement?

Under the Amended Supreme Court Rule 794(d), Illinois attorneys will be required to take one hour of diversity and inclusion CLE and one hour of mental health and substance abuse CLE as part of their six- hour professional responsibility requirement. The amended Rule describes the substantive areas in slightly different language than used in current 794(d) and the new language will be referred to in these FAQs as “diversity/inclusion” and “mental health/substance abuse.” 2. What is the rationale for this new requirement?

In Supreme Court Rule 794(d), the Supreme Court requires Illinois lawyers to take six hours of professional responsibility CLE, which includes, as two of five optional areas, the topical issues of both diversity and mental illness and substance abuse. Data collected by the Illinois Supreme Court Commission on Professionalism shows that few attorneys take courses focused on either of those two areas. The new requirement will use education as a tool to encourage attorneys to seek more information and engagement on diversity and mental health and substance abuse issues. Please see the Commission on Professionalism’s recommendation letter to the Court for further discussion.

3. When does the new requirement go into effect?

The Rule’s effective date is July 1, 2017 and begins with the two-year reporting period ending June 30, 2019. No courses offered or activities taken prior to July 1, 2017 will be eligible for the new diversity/inclusion and mental health/substance abuse CLE requirement. 4. Who will administer the new requirement?

The Illinois Supreme Court Commission on Professionalism will continue to administer the entire professional responsibility requirement. 5. Do newly-admitted attorneys have to fulfill this requirement?

No, this new requirement will not apply to newly-admitted attorneys. New attorneys will continue to have to complete their newly-admitted attorney requirement. Please see this MCLE Board FAQ for additional information on the newly-admitted attorney requirement. 6. Does completing the Supreme Court’s lawyer-to-lawyer mentoring program meet the diversity and mental health and substance abuse CLE requirement?

Yes. Under Amended Rule 794(d)(2), completing the Court’s mentoring program as a mentor or mentee will fulfill the new CLE requirement. Attorneys can find out more information about the mentoring program on the Illinois Supreme Court Commission on Professionalism’s website. 7. What courses will qualify for diversity/inclusion or mental health/substance abuse CLE credit?

The provider offering the course will identify the course as offered to fulfill the diversity/inclusion or mental health/substance abuse CLE credit, in the same way that courses are currently identified for professional responsibility CLE credit. The Commission on Professionalism will continue to review and approve the content of such courses as fulfilling the professional responsibility CLE requirement. The Commission on Professionalism’s Professional Responsibility Education Guide explains that courses geared to promoting diversity, inclusion, and increased mental health and preventing substance abuse are approved by the Commission (and will continue to be approved) for professional responsibility CLE credit. Our website will be revised to reflect the slightly different language used in the new Rule to describe these two substantive areas of professional responsibility CLE. A revised version of this Guide will be promulgated by July 1, 2017 to offer more detailed guidance on courses that will be approved to fulfill the new diversity/inclusion and mental health/substance abuse requirement. 8. Do out-of-state courses qualify for diversity/inclusion or mental health/substance abuse CLE credit?

Yes. Under Rule 795(c)(5), attorneys can receive Illinois CLE credit for CLE courses taken outside of Illinois as long as the provider did not seek Illinois credit for the program. Attorneys seeking credit for a professional responsibility course must first complete an MCLE Board application. Once they receive approval from the Board, they must then complete a professional responsibility out-of-state CLE

application with the Commission on Professionalism and request diversity and inclusion or mental health and substance abuse CLE credit. The new application forms will be available by July 1, 2017. 9. Do non-traditional courses qualify for diversity/inclusion or mental health/substance abuse CLE credit

Yes. Under Rule 795(d), attorneys can receive CLE credit by attending or participating in certain “non- traditional” courses or activities. To request diversity/inclusion or mental health/substance abuse CLE credit, attorneys must complete a professional responsibility non-traditional CLE application and request such CLE credit. The new application forms will be available by July 1, 2017. 10. How can attorneys locate courses offered for diversity/inclusion or mental health/substance abuse CLE credit?

Attorneys can locate courses through their customary providers, including the Lawyers Assistance Program and the Commission on Professionalism, or use the MCLE Board Course Search to search for courses that offer diversity/inclusion or mental health/substance abuse CLE credit. The search ability will be available by July 1, 2017. 11. Are there any free online diversity/inclusion or mental health/substance abuse CLE courses?

The Lawyers’ Assistance Program offers several one-hour mental health/substance abuse online courses. The Illinois Supreme Court Commission on Professionalism will offer a one-hour diversity and inclusion online course in summer 2017.

FAQs for Providers 1. What is the new diversity/inclusion and mental health/and substance abuse CLE requirement?

Under the Amended Supreme Court Rule 794(d), Illinois attorneys will be required to take one hour of diversity and inclusion CLE and one hour of mental health and substance abuse CLE as part of their six- hour professional responsibility requirement. The amended Rule describes the substantive areas in slightly different language than used in current 794(d), and the new language will be referred to in these FAQs as “diversity/inclusion” and “mental health/substance abuse.” 2. What is the rationale for this new requirement?

In Supreme Court Rule 794(d), the Supreme Court requires Illinois lawyers to take six hours of professional responsibility CLE, which includes, as two of five optional areas, the topical issues of both diversity and mental illness and substance abuse. Data collected by the Illinois Supreme Court Commission on Professionalism shows that few attorneys take courses focused on either of those two areas. The new requirement will use education as a tool to encourage attorneys to seek more information and engagement on diversity and mental health and substance abuse issues. Please see the Commission on Professionalism’s Recommendation to the Court for further discussion.

3. When does the new requirement go into effect?

The Illinois Supreme Court Commission on Professionalism will continue to administer the entire professional responsibility requirement. 5. What courses will qualify for diversity/inclusion and mental health/substance abuse CLE credit?

The Commission on Professionalism will continue to review and approve the content of such courses as fulfilling the professional responsibility CLE requirement. The Commission on Professionalism’s Professional Responsibility Education Guide explains that courses geared to promoting diversity, inclusion, and increased mental health and preventing substance abuse are approved by the Commission (and will continue to be approved) for professional responsibility CLE credit. Our website will be revised to reflect the slightly different language used in the new Rule to describe these two substantive areas of professional responsibility CLE. A revised version of this Guide will be promulgated by July 1, 2017 to offer more detailed guidance on courses that will be approved to fulfill the new diversity/inclusion and mental health/substance abuse requirement. 6. How can a provider identify a course for diversity/inclusion or mental health/substance abuse CLE credit?

Providers will continue to use the same MCLE PCAM Professional Responsibility application that they have used in the past. Providers will select one of five professional responsibility areas for each professional responsibility segment of the program. The new system will be in place by July 1, 2017. 7. Do providers have to offer certificates of attendance and teaching stating that a course offered diversity/inclusion or mental health/substance abuse CLE credit?

Yes. Providers can offer certificates of attendance and teaching that state that the attorney earned a specified number of professional responsibility credit hours, including a specified number of diversity/inclusion or mental health/substance abuse CLE credit hours. Sample certificates will be available by July 1, 2017. 8. Can providers advertise a course as offering diversity/inclusion or mental health/substance abuse CLE credit?

Yes, providers can advertise in the same way they currently do for professional responsibility CLE credit.

If you have any further questions about the new requirement, please contact the Illinois Supreme Court Commission on Professionalism at (312) 363-6210 or email Lindsay Shaw.

4 Our Mission To promote a culture of civility and inclusion, in which Illinois lawyers and judges embody the ideals of the legal profession in service to the administration of justice in our democratic society.

Professional Responsibility Education Guide

Professional Responsibility Topics Rule 794(d) defines professional responsibility courses as those in the areas of professionalism, civility, legal ethics, diversity and inclusion, and mental health and substance abuse. Each of these areas is discussed separately below. As of July 1, 2017, Illinois attorneys are required to take one hour of diversity and inclusion CLE and one hour of mental health and substance abuse CLE during each two-year reporting period.

In addition, please remember that every professional responsibility course must still meet Rule 795 accreditation standards.

Diversity and Inclusion

The legal profession continues to face challenges with the diversity of our profession. The Court is concerned about these challenges and the impact it has on our justice system. Through diversity and inclusion education, the Commission encourages our legal community to explore prejudices and biases, both personal and institutional, and to develop strategies for changing behavior. Diversity and inclusion CLE programs provide excellent opportunities to engage in small group interactive sessions.

When designing a diversity and inclusion CLE program offered for credit in Illinois, providers should be aware of the following guidelines:

• Diversity and inclusion CLE should focus on challenges faced by groups underrepresented in the legal profession.

• Courses should focus on eliminating bias, increasing representation, reducing harassment, and barriers to hiring, retention, promotion, professional development and full participation of underrepresented groups in the legal profession. • Like all CLE courses, a diversity CLE course must directly relate to issues in the legal profession and in the practice of law. Credit will not be given to courses that are not specifically oriented toward attorneys.

• Courses should have practical advice to participants that they can utilize and employ when improving diversity and inclusion in their professional circles. If a panel is utilized, the panelists should have personal and/or professional experience with diversity and inclusion and offer unique insight into the challenges facing the legal profession and the justice system. Valid and measurable research should be utilized where possible.

• Courses should include interactive activities to allow participants to engage with each other while learning diverse perspectives and challenging their own biases.

• Programs about substantive law as it relates to representing clients from underrepresented groups will not qualify for professional responsibility CLE credit. For example, courses focused on immigration laws, the tax code and divorce law would not qualify for professional responsibility credit. Programs addressing communication skills necessary for effective representation of diverse clients could qualify under the “professionalism” topic area.

Examples of diversity and inclusion courses include:

• Challenging implicit biases

• Advancing women in the profession

• Restructuring organization policies to encourage retention

• Mentoring relationships between majority and minority attorneys

• Client-initiated efforts to increase diversity of lawyers

• Under the previous Rule 795(d), the Supreme Court had included “diversity” as one of five optional areas of professional responsibility CLE credit. At the request of our providers, titles of courses that had been previously approved for professional responsibility credit under this topic area include:

• Positive Steps to Increase Gender Diversity and Eliminate Bias in the Legal Profession • Overcoming and Eliminating Age Bias against both Younger and Older Lawyers, with a Discussion of ABA Model Rule 8.4(g)

• Leadership, Diversity, and Inclusion: Uncovering the Talent in Your Team

• The Metrics of Diversity Initiatives: How Can We Measure Progress?

• Changing Workplace Culture: Creating LGBT Inclusive Workplaces

Mental Health and Substance Abuse

Judges and lawyers suffer from mental health and substance abuse issues at a significantly higher rate than does the general population. Providers should utilize mental health and substance abuse CLE programming to explore ways to increase the health and well-being of the bar. Like all CLE courses, a mental health and substance abuse course must directly relate to issues in the legal profession and in the practice of law. Credit will not be given to courses that are not specifically oriented toward attorneys.

Course providers may share the role of Lawyers’ Assistance Programs and include either this Illinois LAP slide or this non-state specific CoLAP slide in their PowerPoint presentations. Examples of topics for a mental health and substance abuse course include:

• balancing personal and professional priorities

• maintaining emotional and mental health

• stress management

• suicide prevention

• recognizing signs and symptoms of mental health and substance abuse

• strategies for dealing with mental health and substance abuse

• the relationship between mental health and substance abuse and disciplinary actions

• the effects of lawyer impairment on our profession • destigmatizing mental health and substance abuse

Under the previous Rule 795(d), the Supreme Court had included “mental illness and substance abuse” as one of five optional areas of professional responsibility CLE credit. At the request of our providers, titles of courses that had been previously approved for professional responsibility credit under this topic area include:

• Mental Health, Substance Abuse and Competency: What’s the connection?

• Stress Management for Lawyers

• Living in the Dark: A Look at Depression, Alcoholism and Suicide in the Legal Profession

• Ethical Issues in Making Capacity Decisions

• Better Lawyering Through Mindfulness

Civility

Reducing attorney incivility in Illinois lies at the heart of the Commission’s mission. Incivility results when lawyers erroneously equate aggressiveness with advocacy. Further, lawyers who act with single-minded aggressiveness in representing a client often fail to fulfill the simultaneous duties they owe to the court, to the rule of law, to the administration of justice, and to the public good. Examples of topics for a civility course include:

• how to alleviate incivility in the profession

• how to engage in difficult conversations (e.g. using reframing skills)

• how to defuse highly charged situations

• how to conduct a civil deposition or mediation

• At the request of our providers, titles of civility courses that have been previously approved for professional responsibility credit include:

• Practicing Civility and Constructive Ways to Deal with Those Who Don’t

• Hamilton: An American Lawyer – Lessons for Your Practice • Taking the High Road: How to Deal Ethically with Bullies Who Don’t Play by the Rules

• Civil Discourse: What Would George Washington Say?

• Ethics, Civility, Diversity, and Discovery: Being Nice and Being Careful

Professionalism

Professionalism calls us to be mindful of the lawyer’s roles as officer of the legal system, advocate, counselor, negotiator, and problem solver. Professionalism asks us to commit to improving the law, the legal system, and access to that system. These values make us a profession enlisted in service not only to the client, but to the administration of justice and to the public good. Providers should incorporate those principles and values into their professionalism programming.

Examples of topics for a professionalism course include:

• The relationship between legal practice and technology

• Motion and trial practice, deposition training, negotiation strategies, settlement simulations, mediation

• Effective legal research techniques

• Law practice management

• Client communication and client relations

• Techniques to address the misuse and abuse of discovery and litigation

• Billable hours and responsible fees

• Pro bono training

At the request of our providers, titles of professionalism courses that have been previously approved for professional responsibility credit include:

• Negotiation Success Series

• Fundamentals of Effective Client Communication

• Settings & Customizations for Lawyers Using Android

• Hands-On: Create Charts for Your Cases in Microsoft Excel

• The Art & Science of Criminal Defense: Expert Advice to Sharpen Your Skills

Legal Ethics

The Rules of Professional Conduct establish minimal ethical standards that every lawyer must comply with in order to promote the highest standards of the legal profession.

Examples of topics for a legal ethics course include:

• conflict between duty to client and duty to the system of justice or to the public good

• conflict between duty to client and duty to opposing attorney

• attorney’s responsibilities as an officer of the legal system

• spotting and avoiding malpractice

• other duties and responsibilities articulated in the Rules of Professional Conduct

• At the request of our providers, titles of legal ethics courses that have been previously approved for professional responsibility credit include:

• I Could Get Away with an Ethics Violation, But SHOULD I Do It?

• Let’s Get Technical: Digital Security Ethics for Law Firms

• From a Different Perspective: The Ethical Challenge Presented by Social Media Metadata

• Conflicts of Interest: A Practical Legal Ethics Guide

• Ethics of Going Into Business With Clients

Professional Responsibility Course Design

Effective adult education has little to do with the transfer of knowledge from a single expert or lecture from a podium that we traditionally associate with legal education. Adults learn best by puzzling through possible courses of action in light of actual practice situations and from hearing the wisdom and perspectives of experienced participants.

Successful providers and facilitators utilize hypotheticals, factual scenarios, role play and simulations to fully immerse their participants in professional responsibility learning. The goal is to equip lawyers with tools to transform their careers to manifest the highest ideals of our profession.

Specifically, professional responsibility education:

• Informs lawyers about how to apply the core values and ethical responsibilities of our profession in various settings

• Encourages lawyers to engage in dialogue with their fellow attendees

• Allows lawyers to apply the lessons of the course to their own professional situations

• Provides lawyers with practical takeaways to utilize for a more professional life

Learning Objectives

All professional responsibility courses need concrete learning objectives where the provider identifies actions or behaviors that participants will be able to do as a result of the course. The learning objectives should not focus on what the presenter wishes to teach, or “cover,” but on what the participant will learn. Best practice learning objectives state, “Participants will learn to ….”

Design the course so that learning objectives will be met. If one of your goals is that participants be able to do something when they leave, then the class should contain an activity where participants actually perform that task. Hypotheticals, factual scenarios, role play and simulations are particularly suitable course formats for exploring topics in the area of professional responsibility. For example, if the course is on avoiding ethical conflicts of interest, include several hypotheticals or scenarios in the presentation, as well as the language of the relevant Rules of Professional Conduct, so that the participants can actually apply the applicable Rules to the hypothetical situation.

Basic Skills Course

Requirements for newly-admitted attorneys include a Basic Skills Course consisting of at least 6 hours of education dedicated to professional responsibility topics and issues. Providers’ CLE accreditation applications should provide sufficient information for us to determine whether appropriate professional responsibility topics are included in the plan for the Basic Skills Course. New attorneys may satisfy this professional responsibility requirement through a mentoring program approved by the Commission.

Success Vision

Successful professional responsibility courses will:

• Create in attorney attendees a habit of talking with colleagues and engaging in dialogue about professional responsibility topics

• Encourage in lawyers the habit of reflection (or the ‘stop and think’ rule of morality)

• Introduce lawyers to the changing drivers in the profession and equip them to cope with these realities

• Expand lawyers’ horizons with respect to the richness and variety of the legal profession

Most importantly, each and every professional responsibility course should be designed to stimulate the lawyer’s imagination about the boundless potential of a professional life.

Contact We hope you have found these guidelines helpful. Please contact Michelle Silverthorn if you have any questions or comments. https://www.2civility.org/programs/cle/professional-responsibility-cle-guidelines/

Links to Regulator Rules and FAQs ______

Alabama State Bar MCLE Commission: Rules and Regulations & FAQs

Alaska Bar Association: MCLE Rule

State Bar of Arizona: MCLE Regulations & FAQs

Arkansas Continuing Legal Education Board: Rules and Regulations

The State Bar of California: MCLE Rules & FAQs

Colorado Supreme Court Board of Continuing Legal and Judicial Education: CLE Rules, Regulations and Forms & FAQs

Connecticut Judicial Branch: Rules & FAQs

The Commission on Continuing Legal Education of the Supreme Court of Delaware: Rules & FAQs

The Florida Bar: CLER Rules & FAQs

State Bar of Georgia: Regulation & FAQs:

Hawaii State Bar Association: Regulations & FAQs:

Idaho State Bar: Rules & Info

Minimum Continuing Legal Education Board of the Supreme Court of Illinois: Rules & FAQs

Indiana Commission for Continuing Legal Education: Rules & FAQs

Iowa Supreme Court Commission on Continuing Legal Education: Regulation 41 Regulation 42 & FAQs

Kansas Continuing Legal Education Commission: Rules & FAQs

Kentucky Bar Association: Rules & FAQs

Louisiana Bar Association Committee on Mandatory Continuing Legal Education: Rules

ACLEA/CLEreg Joint Session, July 2018

Maine Board of Overseers of the Bar: Rules & FAQs

Minnesota State Board of Continuing Legal Education: Rules & FAQs

Mississippi Commission on Continuing Legal Education: Rules & FAQs:

The Missouri Bar: Rules & FAQs

Supreme Court of Montana: Rules & FAQs

State of Nebraska Judicial Branch: Rules

Nevada Board of Continuing Legal Education: Rules & FAQs

New Hampshire Continuing Legal Education Board: Rules & FAQs

Supreme Court of New Jersey Board on Continuing Legal Education: Rules & FAQs

New Mexico Minimum Continuing Legal Education Agency: Rules & FAQs

New York State Continuing Legal Education Board: Program Rules, Regulations & Guidelines & FAQs

North Carolina State Bar Continuing Legal Education Department: Rules & FAQs

North Dakota Commission for Continuing Legal Education: Rules & FAQs

Commission on Continuing Legal Education, Supreme Court of Ohio: Rules & FAQs

Oklahoma Bar Association MCLE Commission: Rules & FAQs

Oregon State Bar: Rules & FAQs

Pennsylvania Continuing Legal Education Board: Rules & FAQs

La Rama Judicial de Puerto Rico: Rules & FAQs

Rhode Island Mandatory Continuing Legal Education Commission: Rules & FAQs

The Supreme Court of South Carolina Commission on CLE and Specialization: Rules & FAQs

Tennessee Commission on Continuing Legal Education and Specialization: Rules & FAQs

State Bar of Texas: Rules & FAQs

ACLEA/CLEreg Joint Session, July 2018

Utah State Board of Continuing Legal Education: Rules & Info & FAQs

Vermont MCLE Board: Rules & FAQs

Virgin Islands Bar Association: Rules & Info

Virginia State Bar: Rules & FAQs

Washington State Bar Association: Rules, Info & FAQs

West Virginia State Bar: Rules & Regulations

Supreme Court of Wisconsin Board of Bar Examiners: Rules & FAQs

Wyoming State Bar: Rules & FAQs

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Learn More. CLEreg.org Tel 317.340.3088 Email: [email protected] WWW.CLEREG.ORG/MCLE-GUIDE/REGISTER Standalone MCLE Credit Categories

The following are examples of standalone MCLE credit categories and requirements that exist beyond the standard categories of general, professional practice, ethics, and professional responsibility. All rules, regulations, and guidance are from published resources. Consult your jurisdiction for final authority. California

The State Bar of California requires attorneys to complete 1 credit in the category of “Competence Issues” and 1 credit in the category of “Elimination of Bias” as part of their three- year compliance period1.

Competence Issues: Must address substance abuse or other mental or physical issues that impair a member’s ability to perform legal services with competence2.

Approved activities must consist of education that identifies and discusses the detection of substance abuse, mental illness or other mental or physical issue that impairs an attorney's ability to perform legal services with competence.

Courses that discuss or provide treatment for any of the mental, emotional or physical issues that affect professional competence do not qualify for credit in this area. This includes programs primarily about alcohol and drug treatment, meditation or other forms of stress management3.

Recognition and Elimination of Bias in the Legal Profession and Society: Content must deal with the recognition and elimination of bias in the legal profession and society by reason of, but not limited to, sex, color, race, religion, ancestry, national origin, physical disability, age, or sexual orientation4.

Activities that qualify include courses on any form of bias found in the legal profession or in society in general. Activities that qualify for credit include education in the recognition and elimination of impermissible bias in the courtroom, law office, attorney-client relationships and

1 “MCLE Requirements.” State Bar of California, n.d. http://www.calbar.ca.gov/Attorneys/MCLE-CLE/Requirements Accessed July 20th, 2018 2 “TITLE 2. RIGHTS AND RESPONSIBILITIES OF MEMBERS” The State Bar of California, Adopted July 2007, Amended effective February 1, 2018, www.calbar.ca.gov/Portals/0/documents/rules/Rules_Title2_Div4-MCLE.pdf Accessed July 25th, 2018 3 “Qualifying MCLE Activities for Providers” The State Bar of California, n.d., www.calbar.ca.gov/Attorneys/MCLE-CLE/MCLE- Providers/Qualifying-Activities Accessed July 25, 2018 4 “TITLE 2. RIGHTS AND RESPONSIBILITIES OF MEMBERS” The State Bar of California. n.d. www.calbar.ca.gov/Portals/0/documents/rules/Rules_Title2_Div4-MCLE.pdf Accessed July 25th, 2018 relationships with other attorneys, legal and nonlegal employment, the workplace, hiring, managing and terminating employees and in housing, accommodations and services.

Courses required by AB 1825 (mandatory sexual harassment awareness and prevention training for personnel managers) are approved for elimination of bias credit5. Florida

The Florida Bar requires attorneys to complete 5 credits in legal ethics, professionalism, bias elimination, substance abuse, or mental illness awareness and 3 credits in the new category of technology as part of their three-year compliance period6.

Bias Elimination: Credit may be awarded for courses that address standards of conduct in the legal profession related to the recognition and elimination of bias, such as gender, ethnicity, religion, disabilities, age, or sexual orientation. Courses should educate lawyers as to the aspirations that surpass ordinary expectations to further promote the ideals and goals of professionalism7.

Substance Abuse: Credit may be awarded for courses designed to enhance awareness and understanding of substance abuse and dependence disorders.

(1) Topics eligible for credit in this category include education regarding the mechanisms involved in substance abuse and dependence disorders as described in the Diagnostic and Statistical Manual of The American Psychiatric Association.

(2) Instruction may address the correlation between substance abuse/dependence disorders and professional misconduct, malpractice, and disciplinary actions; identification of the signs and symptoms of substance abuse/dependence disorders; types of intervention and treatment for substance abuse/dependence disorders among lawyers, including the lawyer assistance program available to Florida legal professionals8.

Mental Illness Awareness: Credit may be awarded for courses designed to enhance awareness and understanding of mental illness. (1) Topics eligible for credit in this category include depression, manic-depression (bipolar disorder), schizophrenia, and anxiety disorders, including

5 “Qualifying MCLE Activities for Providers” The State Bar of California, n.d. www.calbar.ca.gov/Attorneys/MCLE-CLE/MCLE- Providers/Qualifying-Activities Accessed July 25, 2018 6 “5.09 CLER COMPONENTS APPROVAL GUIDELINES” Supreme Court of Florida, n.d. http://www.floridasupremecourt.org/decisions/2016/sc16- 574.pdf Accessed July 25, 2018 7 “Accreditation Standards” BLSE Standing Policies, n.d. https://www.floridabar.org/wp-content/uploads/2017/04/BLSE-Standing-Policies-500- Series.pdf Accessed July 26, 2018 8 “Accreditation Standards” BLSE Standing Policies, n.d. https://www.floridabar.org/wp-content/uploads/2017/04/BLSE-Standing-Policies-500- Series.pdf Accessed July 26, 2018 obsessive-compulsive disorders. (2) Eligible courses must address relationships among mental illness, addiction, or substance abuse due to “self-medication;” the prevention of suicide, aggressive behavior, criminal activities, and underachievement through prompt and faithful medical treatment; and the progressive deterioration of the brain and/or the increase in the severity of symptoms and accompanying problematic behaviors without proper medical treatment9.

Technology: Competent representation may also involve the association or retention of a non- lawyer advisor of established technological competence in the field in question. Competent representation also involves safeguarding confidential information relating to the representation, including, but not limited to, electronic transmissions and communications. To maintain the requisite knowledge and skill, a lawyer should keep abreast of changes in the law and its practice, engage in continuing study and education, including an understanding of the benefits and risks associated with the use of technology, and comply with all continuing legal education requirements to which the lawyer is subject10.

Per 5.09(g) CLER COMPONENTS APPROVAL GUIDELINES: Credit may be awarded for courses that include information on technology tools, programs, or applications to assist lawyers in their law practice. Examples include legal research programs, office and document preparation applications, litigation software applications, file retention or storage applications, billing programs, web and internet security and encryption methods, and communication tools.

Technology topics must focus on or highlight their use in the practice of law. The content of a course on technology is generally eligible for credit if it:

(1) includes legal content (e.g., law involving technology such as privacy or intellectual property);

(2) is tailored primarily for lawyers (e.g., adherence to the Rules of Professional Conduct when using the technology, the risks and/or benefits or using the technology as a lawyer, and/or teaching about or discussion of situations encountered when a lawyer uses the technology in conjunction with the lawyer’s practice); or,

(3) includes course content that conveys general information on the features and use of technology by a lawyer, or presents issues, situations, risks, benefits and ethical considerations of using the technology as a lawyer.

Courses also may qualify for credit if they address the “how to” of using any technology in the practice of law. This may include general technology programs tailored for a lawyer audience or

9 “Accreditation Standards” BLSE Standing Policies, n.d. https://www.floridabar.org/wp-content/uploads/2017/04/BLSE-Standing-Policies-500- Series.pdf Accessed July 26, 2018 10 “5.09 CLER COMPONENTS APPROVAL GUIDELINES” The Florida Bar, n.d. https://www.floridabar.org/wp-content/uploads/2017/04/BLSE- Standing-Policies-500-Series.pdf Accessed on July 25, 2018 application. For example, a course on a document preparation application might show how the application can facilitate the preparation of an appellate course brief and compliance with limitations of length. Another example is a course which assists a lawyer to use electronic court filing programs. The key is that the course is relevant and has a demonstrable application to the practice of law.

Credit will not be awarded for course content consisting of marketing of a technology product or service. Georgia

The State Bar of Georgia requires 1 credit of professionalism every annual compliance period. The Georgia Supreme Court has distinguished between ethics and professionalism, while creating separate one-hour CLE requirements for each. Georgia also requires trial attorneys to earn 3 trial credits as part of their requirement11.

Professionalism: Qualifying topics include: access to justice; administration of justice; advocacy - effective persuasive advocacy techniques for trial, appellate, and other representation contexts; alternative dispute resolution - negotiation, settlement, mediation, arbitration, early neutral evaluation, other dispute resolution processes alternative to litigation; billable hours; civility; client communication skills; client concerns and expectations; client relations skills; commercial pressures; communication skills (oral and written); discovery - effective techniques to overcome misuse and abuse; diversity and inclusion Issues - age, ethnic, gender, racial, sexual orientation, socioeconomic status; mentoring; proficiency and clarity in oral, written, and electronic communications - with the court, lawyers, clients, government agencies, and the public; public interest; quality of life issues - balancing priorities, career/personal transition, maintaining emotional and mental health, stress management, substance abuse; responsibility for improving the administration of justice; responsibility to ensure access to the legal system; responsibility for performing community, public and pro bono service; restoring and sustaining public confidence in the legal system, including courts, lawyers, the systems of justice; law practice management - issues relating to development and management of a law practice including client relations and technology to promote the efficient, economical and competent delivery of legal services, in accordance with Regulation (11) to Rule 8-106(B) of the Rules and Regulations for Organization and Government of the State Bar of Georgia12:

Practice Management CLE includes, but is not limited to, those activities which (1) teach lawyers how to organize and manage their law practices so as to promote the efficient,

11 “Frequently Asked Questions” State Bar of Georgia, n.d., www.gabar.org/aboutthebar/faq/faqs.cfm?filter=Mandatory%20Continuing%20Legal%20Education# Accessed on July 25, 2018 12 “Issues and Topics” State Bar of Georgia, n.d., www.gabar.org/membership/cle/professionalism.cfm#issues Accessed on July 25, 2018 economical and competent delivery of legal services; and (2) teach lawyers how to create and maintain good client relations consistent with existing ethical and professional guidelines so as to eliminate malpractice claims and bar grievances while improving service to the client and the public image of the profession.

Trial: Each active member who appears as sole or lead counsel in the Superior or State Courts of Georgia in any contested civil case or in the trial of a criminal case in 1990 or in any subsequent calendar year, shall complete for such year a minimum of three (3) hours of continuing legal education activity in the area of trial practice.

A trial practice CLE activity is one exclusively limited to one or more of the following subjects: evidence, civil practice and procedure, criminal practice and procedure, ethics and professionalism in litigation, or trial advocacy. These hours are to be included in, and not in addition to, the 12-hour (twelve) requirement. If a member completes more than three (3) trial practice hours, the excess trial practice credit may be carried forward and applied to the trial practice requirement for the succeeding year only13. Illinois

The MCLE Rules of the Supreme Court of Illinois requires attorneys to complete one credit in the category of “diversity and inclusion” and one credit in the category of “mental health and substance abuse” as part of their professional responsibility requirement. The Minimum Continuing Legal Education Board of the Supreme Court of Illinois operates the Court’s MCLE program, including reviewing course applications for general credit and the Commission on Professionalism reviews applications for professional responsibility credit.

Mental Health and Substance Abuse: Per the Illinois Supreme Court Commission on Professionalism, “mental health and substance abuse course must directly relate to issues in the legal profession and in the practice of law. Credit will not be given to courses that are not specifically oriented toward attorneys.14”

Diversity and Inclusion: Programs must focus on the legal profession. Per the Illinois Supreme Court Commission on Professionalism:

“courses should focus on eliminating bias, increasing representation, reducing harassment, and barriers to hiring, retention, promotion, professional development and full participation of underrepresented groups in the legal profession.

13 “State Bar of Georgia Handbook” Georgia Bar Journal, Special Issue—2016-2017 Handbook, www.gabar.org/barrules/upload/1617Handbook_web.pdf Accessed July 25, 2018 14 “Professional Responsibility Education Guide” Illinois Supreme Court Commission on Professionalism, n.d., www.2civility.org/programs/cle/professional-responsibility-cle-guidelines/ Accessed July 25, 2018 “Programs must directly relate to the legal profession and in the practice of law. Credit will not be given to courses that are not specifically oriented toward attorneys.

“Courses should have practical advice to participants that they can utilize and employ when improving diversity and inclusion in their professional circles. If a panel is utilized, the panelists should have personal and/or professional experience with diversity and inclusion and offer unique insight into the challenges facing the legal profession and the justice system. Valid and measurable research should be utilized where possible.”

Examples of qualifying topics include: challenging implicit biases; advancing women in the profession; restructuring organization policies to encourage retention; mentoring relationships between majority and minority attorneys; and client-initiated efforts to increase diversity of lawyers15. Indiana

The Indiana Commission for Continuing Legal Education allows attorneys to earn up to 12 hours of Non Legal Subject Matter Course (NLS) credits as part of their three-year compliance period.

Non Legal Subject Matter (NLS): Courses that the Commission approves for Non Legal Subject Matter credit pursuant to Section 3(a) of this Rule because, even though they lack substantive legal content, they nonetheless enhance an attendee's proficiency in the attorney's practice of law. The following is a non-exclusive list of courses that may be accredited under this section:

(A) Law Firm Management Courses. A Sponsor may apply for accreditation of a law office management course that does not meet the criteria of (b)(1)(v)) Ethics Concentrated Law Firm Management courses (above). To be accredited, the course must deal with law firm management as opposed to office management in general. Further, the course must be directed to Attorneys or law office administrators. Any portions of the course dealing mainly with profit enhancement or marketing of services will be denied credit16.

Kansas The Kansas Continuing Legal Education Commission allows attorneys to complete up to 2 hours of law practice management (LPM) programming as part of their annual requirement17.

15 “Professional Responsibility Education Guide” Illinois Supreme Court Commission on Professionalism, n.d., www.2civility.org/programs/cle/professional-responsibility-cle-guidelines/ Accessed July 25, 2018 16 “Rule 29. Mandatory Continuing Legal Education” The Bar of Indiana, Including Amendments Received Through March 15, 2018 www.in.gov/judiciary/rules/ad_dis/index.html#_Toc477259921 Accessed on July 25, 2018 17 “RULE 801 CONTINUING LEGAL EDUCATION COMMISSION” The Kansas Continuing Legal Education Commission, July 2017, https://www.kscle.org/pdf/rules08.pdf Accessed on July 25, 2018. Law Practice Management: Qualified programming includes: issues relating to the development and management of a law practice, including client relations and technology to promote the efficient, economical, and competent delivery of legal services18. Louisiana

The Louisiana Bar Association Committee on Mandatory Continuing Legal Education requires attorneys to complete 1 credit of professionalism as part of the annual requirement. Newly admitted attorneys are required to earn at least eight credits in legal ethics, professionalism, or law office management.

Professionalism: Professionalism concerns the knowledge and skill of the law faithfully employed in the service of client and public good, and entails what is more broadly expected of attorneys. It includes courses on the duties of attorneys to the judicial system, courts, public, clients, and other attorneys; attorney competency; and pro bono obligations19.

Law Office Management: Law office management concerns knowledge and skill of office practice including courses on how to: Open and operate a client trust account; Establish a calendar (tickler) system; Communicate with clients; Set fee arrangements, send engagement letters, and establish billing procedures; Avoid and/or obtain help for substance abuse problems; Supervise staff; Organize files; Utilize a conflicts check system; Handle a disciplinary complaint; Terminate representation; and Return files20. Minnesota

The Minnesota State Board of Continuing Legal Education requires attorneys to complete 2 credits in the category of “elimination of bias” as part of the three-year compliance period.

Elimination of Bias: Course must be directly related to the practice of law that is designed to educate attorneys to identify and eliminate from the legal profession and from the practice of law biases against persons because of race, gender, economic status, creed, color, religion, national origin, disability, age or sexual orientation21.

18 “Guidelines for Accreditation of Law Practice Management Programming” The Kansas Continuing Legal Education Commission, July 2017, https://www.kscle.org/pdf/GuidelinesForAccreditatioOfLawPracticeManagementProgramming.pdf Accessed on July 25, 2018 19 “Rules for Continuing Legal Education” Louisiana State Bar, n.d. www.lsba.org/MCLE/ContinuingLegalEducationRules.aspx Accessed on July 25, 2018 20 “Rules for Continuing Legal Education” Louisiana State Bar, n.d. www.lsba.org/MCLE/ContinuingLegalEducationRules.aspx Accessed on July 27, 2018 21 “Rules of the Board of Continuing Legal Education” Minnesota State Board of Continuing Legal Education, n.d. www.cle.mn.gov/rules/ Accessed on July 25, 2018 Nevada

The Nevada Board of Continuing Legal Education requires attorneys to complete 1 credit in the category of “substance abuse” as part of their annual requirement.

Substance Abuse: shall be exclusively in the area of substance abuse, addictive disorders and/or mental health issues that impair professional competence22.

New York

The New York State Continuing Legal Education Board requires experienced attorneys to complete at least one (1) credit in the category of “diversity, inclusion and elimination of bias” for each biennial compliance period.

Diversity, Inclusion and Elimination of Bias: Topics must relate to the practice of law and may include, among other things, implicit and explicit bias, equal access to justice, serving a diverse population, diversity and inclusion initiatives in the legal profession, and sensitivity to cultural and other differences when interacting with members of the public, judges, jurors, litigants, attorneys and court personnel23. Oregon

The Oregon State Bar requires attorneys to complete at least 1 credit in the combined categories of child abuse and elder abuse reporting during every three-year reporting period. Oregon attorneys must also complete at least 3 credits in the category of “access to justice” credit during every alternate reporting period.

Child and Elder Abuse Reporting: Per OSB MCLE Rules and Regulations 5.600, in order to be accredited as a child abuse and elder abuse reporting activity, the one-hour session must include discussion of an Oregon attorney’s requirements to report child abuse and elder abuse and the exceptions to those requirements24.

OSB MCLE Rule 5.14(b) Child and elder abuse reporting programs must be devoted to the lawyer’s statutory duty to report child abuse and elder abuse (see ORS 9.114)25. Content must

22 “EXHIBIT D AMENDMENT TO SUPREME COURT RULES 210, 212, 213, 215” Nevada Board of Continuing Legal Education, n.d., https://www.nvcleboard.org/pdfs/1_1_17_Supreme_Court_Rule_Changes.pdf Accessed on July 25, 2018 23 “Categories of CLE Credit as Defined in the Program Rules 22 NYCRR 1500.2(c)-(g)” New York State Continuing Legal Education Board n.d. http://ww2.nycourts.gov/sites/default/files/document/files/2018-03/12m%20- %20New%20Category%20of%20Credit%2022%20NYCRR%201500.2%28c%29-%28g%29%20-%20redlined.pdf Accessed on July 26, 2018 24 “Oregon State Bar Minimum Continuing Legal Education Rules and Regulations” Oregon State Bar, n.d. www.osbar.org/_docs/rulesregs/mclerules.pdf Accessed on July 25, 2018 25 “2017 ORS 9.114¹ Mandatory training on duties relating to reporting child abuse and abuse of elderly persons” Oregon State Bar, revised 2017, https://www.oregonlaws.org/ors/9.114 Accessed on July 25, 2018 be on the subject of a lawyer’s statutory duty to report child abuse and elder abuse per Oregon Revised Statutes (ORS) 124.060 (Duty of officials to report elder abuse) 26 and 419B.010 (Duty of officials to report child abuse)27.

Access to Justice: Oregon State Bar Minimum Continuing Legal Education Rules and Regulations 5.14(c) requires an accredited activity pertaining to access to justice be directly related to the practice of law and designed to educate attorneys to identify and eliminate from the legal profession and from the practice of law barriers to access to justice arising from biases against persons because of race, gender, economic status, creed, color, religion, national origin, disability, age or sexual orientation28.

South Carolina

The Supreme Court of South Carolina Commission on CLE and Specialization requires at least 1 substance abuse credit to be completed every three years.

Substance abuse: Rule 408(a) (2) requires that instruction must be devoted exclusively to instruction in substance abuse, mental health issues or stress management and the legal profession29.

Utah

The Utah State Board of Continuing Legal Education requires attorneys to complete at least one credit in the category of “professionalism and civility” every two years. This type of credit counts as one of the 3 ethics credits that is required for each reporting period.

Professionalism and Civility: Rule 14-402(w) “Professionalism and Civility” means conduct consistent with the tenets of the legal profession by which a lawyer demonstrates civility, honesty, integrity, character, fairness, competence, ethical conduct, public service, and respect for the rules of law, the courts, clients, other lawyers, witnesses and unrepresented parties30.

26 “2017 ORS 124.060¹ Duty of officials to report” Oregon State Bar, revised 2017, https://www.oregonlaws.org/ors/124.060 Accessed on July 25, 2018 27 “2017 ORS 419B.010¹ Duty of officials to report child abuse” Oregon State Bar, revised 2017, https://www.oregonlaws.org/ors/419B.010 Accessed on July 25, 2018 28 “Oregon State Bar Minimum Continuing Legal Education Rules and Regulations” Oregon State Bar, As amended effective May 10, 2018, www.osbar.org/_docs/rulesregs/mclerules.pdf Accessed on July 25, 2018 29 “RULE 408 CONTINUING LEGAL EDUCATION AND SPECIALIZATION” The Supreme Court of South Carolina Commission on CLE and Specialization, Last amended by Order dated December 28, 2012, effective January 1, 2013, www.commcle.org/pdf/rule408.pdf Accessed on July 25, 2018 30 “Rule 14-402. Definitions.” Utah State Board of Continuing Legal Education, n.d. www.utcourts.gov/resources/rules/ucja/ch14/04%20mcle/usb14-402.html Accessed on July 25, 2018 Washington

The Washington State Bar Association allows attorneys to earn up to 24 credits per compliance period in the following newly approved subject areas: professional development, personal development and mental health, office management, and improving the legal system31.

Professional Development: Defined in APR11(f)(3)as subjects that enhance or develop a lawyer’s, LLLT’s, or LPO’s professional skills including effective lawyering, leadership, career development, communication, and presentation skills;

Personal Development and Mental Health: Defined in APR11(f)(4) as subjects that enhance a lawyer’s, LLLT’s, or LPO’s personal skills, well-being, and awareness of mental health issues. This includes, stress management, and courses about, but not treatment for, anxiety, depression, substance abuse, suicide, and addictive behaviors;

Office Management: Defined in APR11(f)(5) as subjects that enhance the quality of service to clients and efficiency of operating an office, including case management, time management, business planning, financial management, office technology, practice development and marketing, client relations, employee relations, and responsibilities when opening or closing an office;

Improving the Legal System: Defined in APR11(f)(6) as subjects that educate and inform lawyers, LLLTs, or LPOs about current developments and changes in the practice of law and legal profession in general, including legal education, global perspectives of the law, courts and other dispute resolution systems, regulation of the practice of law, access to justice, and pro bono and low cost service planning; and

Nexus Subject: Defined in APR11(f)(7) as a subject matter that does not deal directly with the practice of law but that is demonstrated by the lawyer, LLLT, or LPO, or sponsor to be related to a lawyer’s, LLLT’s, or LPO’s professional role as a lawyer, LLLT, or LPO32. West Virginia

The West Virginia State Bar requires attorneys to complete at least 3 credits in the categories of legal ethics, office management, substance abuse, or elimination of bias in the legal profession during every two-year compliance period33.

31 “FREQUENTLY ASKED QUESTIONS FOR LAWYERS” Washington State Bar Association, Last Updated: April 4, 2018, www.wsba.org/docs/default-source/licensing/mcle/mcle-faq---with-late-fee-chart.pdf?sfvrsn=bafd07f1_4 Accessed on July 25, 2018 32 “Admission and Practice Rules, Rule 11 Mandatory Continuing Legal Education (MCLE), Approved Activities” Washington Courts n.d. https://view.officeapps.live.com/op/view.aspx?src=http://www.courts.wa.gov/court_rules/Word/gaapr11.doc Accessed on July 26, 2018 33 'MCLE Reporting Period & Requirements" West Virginia State Bar n.d. https://wvbar.org/members/mcle/rules-regulations/mcle-reporting- period-requirements/ Accessed July 26, 2018