Editor’s Note: REBA has filed a 12-page comment letter, prepared by the Ethics Section Co-chairs and approved by the Board of Director in response to the SJC’s Standing Advisory Committee on the Rules of Professional Conduct. The proposed rule revisions have their genesis in the SJC’s 2020 Olchowski decision relating to unidentified and unclaimed funds in IOLTA accounts. REBA, along with many others, submitted adverse comments to the Standing Advisory Committee’s first proposed rule revisions in September 2020. The Committee withdrew its proposed rule revision.
Today, two years later, the Standing Advisory Committee has issued a second proposed rule revision. The Association’s adverse comment letter is below.
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