The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
AMERICAN BAR ASSOCIATION
CENTER FOR INNOVATION
STANDING COMMITTEE ON THE DELIVERY OF LEGAL SERVICES
STANDING COMMITTEE ON ETHICS AND PROFESSIONAL RESPONSIBILITY
STANDING COMMITTEE ON PROFESSIONAL REGULATION
STANDING COMMITTEE ON PUBLIC PROTECTION IN THE PROVISION OF LEGAL
SERVICES
REPORT TO THE HOUSE OF DELEGATES
RESOLUTION
RESOLVED, That the American Bar Association encourages U.S. jurisdictions to
consider innovative approaches to the access to justice crisis in order to help the more
than 80% of people below the poverty line and the majority of middle-income Americans
who lack meaningful access to legal services when facing critical civil legal issues, such
as child custody, debt collection, eviction, and foreclosure.
FURTHER RESOLVED, That the American Bar Association encourages U.S.
jurisdictions to consider regulatory innovations that have the potential to improve the
accessibility, affordability, and quality of civil legal services, while also ensuring
necessary and appropriate protections that best serve the public.
FURTHER RESOLVED, That the American Bar Association encourages U.S.
jurisdictions to consider regulatory innovations that have been adopted or are under
review in a growing number of state supreme courts and that are also under study by
state and local bar associations, such as the authorization and regulation of new
categories of legal services providers, the reexamination of Rule 5.4 of a jurisdiction’s
rules of professional conduct, and the reexamination of provisions related to the
unauthorized practice of law.
FURTHER RESOLVED, That the American Bar Association encourages U.S.
jurisdictions to collect and assess data regarding regulatory innovations both before and
after the adoption of any innovations to ensure that changes are effective in increasing
access to legal services and are in the public interest.

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
REPORT
I.

Introduction

Access to affordable civil legal services is increasingly out of reach across the
United States. More than 80% of people below the poverty line and a majority of middleincome Americans receive inadequate assistance when facing critical civil legal issues,
such as child custody, debt collection, eviction, and foreclosure. 1 Approximately 76% of
civil matters in one major study of ten major urban areas had at least one selfrepresented party.2 Moreover, in rural areas, there are often few, if any, lawyers to
address the public’s legal needs. 3 As a result of these and related problems, the United
States ranks 103rd out of 126 countries in terms of the accessibility and affordability of
civil legal services.4
Traditional solutions to fixing this “access to justice” crisis are not enough. For
decades, the legal profession and the organized bar have called for increased funding
for civil legal aid, more pro bono work, and the recognition of civil Gideon rights that
would afford people a right to a lawyer in matters involving essential civil legal needs
(06A112A).5 These efforts are important and have met with some modest success, but
they have not come close to fixing the problems that exist. In fact, the problems are
becoming more severe.6
The legal profession cannot solve these problems alone. The public needs
innovative models for delivering competent legal services, and such models require the
knowledge and expertise of other kinds of professionals, such as technologists and
experts in the design of efficient and user-friendly services. 7 The existing regulatory
structure for the legal profession, however, increasingly acts as a barrier to the
involvement of other professionals, both within and outside of law firms. Regulators and
bar associations in several states, including Arizona, California, New Mexico, Oregon,
Utah, and Washington, have recognized this problem and are working to address it by
1 LEGAL SERVS. CORP., JUSTICE GAP REPORT: MEASURING THE CIVIL LEGAL NEEDS OF LOW-INCOME
AMERICANS (2017), https://www.lsc.gov/sites/default/files/images/TheJusticeGap-FullReport.pdf.
2 NAT’L CTR. FOR STATE COURTS, THE LANDSCAPE OF CIVIL LITIGATION IN STATE COURTS (2015),
https://www.ncsc.org/~/media/Files/PDF/Research/CivilJusticeReport-2015.ashx.
3 Jack Karp, No Country For Old Lawyers: Rural U.S. Faces A Legal Desert, LAW360 (Jan. 27, 2019),
https://www.law360.com/articles/1121543/no-country-for-old-lawyers-rural-u-s-faces-a-legal-desert.
4 WORLD JUSTICE PROJECT, RULE OF LAW INDEX: CURRENT AND HISTORICAL DATA (2019),
https://worldjusticeproject.org/our-work/research-and-data/wjp-rule-law-index-2019/current-historical-data
(rankings are available in the downloadable spreadsheet).
5 AM. BAR ASS’N, REPORT TO THE HOUSE OF DELEGATES 06A112A
https://www.americanbar.org/content/dam/aba/administrative/legal_aid_indigent_defendants/ls_sclaid_06
A112A.authcheckdam.pdf.
6 See, e.g., Anna E. Carpenter, et al., Studying the “New” Civil Judges, 2018 Wisc. L. Rev. 249, 284
(2018) (noting that “[w]here nearly every party was once represented by counsel, today, the vast majority
of litigants are pro se”).
7 See generally STANFORD LEGAL DESIGN LAB, http://www.legaltechdesign.com/ (last visited Nov. 4, 2019).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
proposing or adopting substantial regulatory innovations. 8 More U.S. jurisdictions are
considering doing the same. In most cases, these jurisdictions are not considering
deregulation, but rather re-regulation. That is, they are working to find ways to revise,
rather than eliminate, regulatory structures so that any new services are appropriately
regulated in the interests of the public.
The regulatory innovations that are emerging around the United States are
designed to spur new models for competent and cost-effective legal services delivery
that improve the quality of justice, but it is not yet clear which, if any, specific regulatory
changes will best accomplish these goals consistent with consumer protection. More
data is needed. For this reason, the Resolution does not recommend amendments to
existing ABA models rules, such as the Model Rules of Professional Conduct. The ABA
should nevertheless play a leadership role by adopting policies that encourage more
state-based regulatory innovations, collecting and analyzing the data from those
innovations, and using the resulting data to shape future reform efforts, including
appropriate changes to or adoption of new ABA model rules and policies.
II.

The Need for Regulatory Innovation

The Resolution calls for U.S. jurisdictions to consider regulatory innovations that
foster new ways to deliver competent and cost-effective legal services and have the
potential to improve the accessibility, affordability, and quality of those services while
retaining necessary and appropriate client and public protections. 9 This Resolution is
consistent with one of the recommendations of the ABA Commission on the Future of
8 See, e.g., ARIZ. TASK FORCE ON THE DELIVERY OF LEGAL SERVS., REPORT AND RECOMMENDATIONS
(2019),
https://www.azcourts.gov/Portals/74/LSTF/Report/LSTFReportRecommendationsRED10042019.pdf?
ver=2019-10-07-084849-750; THE UTAH WORKGROUP ON REGULATORY REFORM, NARROWING THE ACCESSTO-JUSTICE GAP BY REIMAGINING REGULATION (2019), https://www.utahbar.org/wpcontent/uploads/2019/08/FINAL-Task-Force-Report.pdf; Press Release, N.M. Admin. Office of the Courts,
Supreme Court Work Group to Consider Non-attorney Option for Providing Civil Legal Servs. (May 21,
2019),
https://www.nmcourts.gov/uploads/FileLinks/a6efaf23676f4c45a95fdb3d71caea83/News_Release_Worki
ng_Group_to_Consider_Licensed_Legal_Technicians.pdf; Task Force on Access Through Innovation of
Legal Services, CAL. BAR ASS’N, http://www.calbar.ca.gov/About-Us/Who-We-Are/CommitteesCommissions/Task-Force-on-Access-Through-Innovation-of-Legal-Services (last visited Nov. 4, 2019);
Special Committee on Technologies Affecting the Practice of Law, FLA. BAR,
https://www.floridabar.org/about/cmtes/cmte-me104/ (last visited Nov. 4, 2019).
9 See, e.g., AM. BAR ASS’N MODEL REGULATORY OBJECTIVES FOR THE PROVISION OF LEGAL SERVICES
(2016) (identifying public protections that should be considered when exploring regulatory changes, such
as the independence of professional judgment, the protection of privileged and confidential information,
and the accessibility of civil remedies for negligence and breach of other duties owed). Innovations must
include necessary and appropriate protections for the public. Depending on the type of innovation and
services provided, the traditional legal requirements of informed consent, client confidentiality, avoidance
of certain conflicts and disclosure of other conflicts and fiduciary obligations may be appropriate but not
necessary, while in other situations certain core requirements of professional ethics will be both
necessary and appropriate.

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
Legal Services (Commission), which recommended that “[c]ourts … consider regulatory
innovations in the area of legal services delivery.” 10
As noted above, the evidence is clear that existing solutions to the access to
justice crisis are insufficient and that we need new ideas, such as regulatory reforms to
unlock new delivery models. Although the need for change is compelling, the evidence
does not yet support any particular regulatory innovation. For this reason, the resolution
encourages U.S. jurisdictions to consider a few general categories of reform without
endorsing any specific changes.
III.

Categories of Regulatory Innovation

In general, states are currently considering three broad areas of
regulatory reform as part of their efforts to improve the affordability,
accessibility, and quality of civil legal services and civil justice.
A.
Authorizing and Regulating New Categories of Legal Services
Providers
Just as healthcare providers other than doctors can provide services to patients
and reduce healthcare costs, legal service providers other than lawyers can do the
same. Two major ABA reports recently reached a similar conclusion, recommending that
U.S. jurisdictions consider authorizing and appropriately regulating new categories of
legal services providers.
In 2014, the ABA Task Force on the Future of Legal Education concluded that a
broader array of professionals should be permitted to deliver legal services:
Broader Delivery of Legal and Related Services: The delivery of legal and related
services today is primarily by J.D.-trained lawyers. However, the services of
these highly trained professionals may not be cost-effective for many actual or
potential clients, and some communities and constituencies lack realistic access
to essential legal services. To expand access to justice, state supreme courts,
state bar associations, admitting authorities, and other regulators should devise
and consider for adoption new or improved frameworks for licensing or otherwise
authorizing providers of legal and related services. This should include
authorizing bar admission for people whose preparation may be other than the
traditional four-years of college plus three-years of classroom-based law school
education, and licensing persons other than holders of a J.D. to deliver limited
legal services. The current misdistribution of legal services and common lack of
access to legal advice of any kind requires innovative and aggressive
10 AM. BAR ASS’N COMM’N ON THE FUTURE OF LEGAL SERVS., REPORT ON THE FUTURE OF LEGAL SERVICES
IN THE UNITED STATES 6 (2016),
https://www.americanbar.org/content/dam/aba/images/abanews/2016FLSReport_FNL_WEB.pdf
(Recommendation 2).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
remediation.11
More recently, in its final report, the ABA Commission on the Future of Legal Services
concluded that it “supports efforts by state supreme courts to examine, and if they deem
appropriate and beneficial to providing greater access to competent legal services,
adopt rules and procedures for judicially-authorized-and-regulated legal services
providers (LSPs).”12 The Commission offered several examples of these efforts:
Examples of such LSPs include federally authorized legal services providers
[such as those who have long represented individuals before the Social Security
Administration] and other authorized providers at the state level, such as
courthouse navigators and housing and consumer court advocates in New York;
courthouse facilitators in California and Washington State; limited practice
officers in Washington State; limited license legal technicians in Washington
State; courthouse advocates in New Hampshire; and document preparers in
Arizona, California, and Nevada. In some jurisdictions, where courts have
authorized these types of LSPs, these individuals are required to work under the
supervision of a lawyer; in other in-stances, courts, in the exercise of their
discretion, have authorized these LSPs to work independently. In each instance,
the LSPs were created and authorized to facilitate greater access to legal
services and the justice system, with steps implemented to protect the public
through training, exams, certification, or similar mechanisms. 13
There is not yet sufficient evidence to endorse any particular LSP model, so the
Commission merely called for U.S. jurisdictions to consider authorizing new categories
of legal services providers:
The Commission does not endorse the authorization of LSPs in any particular
situation or any particular category of these LSPs. Jurisdictions examining the
creation of a new LSP program might consider ways to harmonize their
approaches with other jurisdictions that already have adopted similar types of
LSPs to assure greater uniformity among jurisdictions as to how they approach
LSPs. Jurisdictions also should look to others to learn from their experiences,
particularly in light of the lack of robust data readily available in some states on
the effectiveness of judicially-authorized-and-regulated LSPs in closing the
access to legal services or justice gap. The Commission urges that the ABA
Model Regulatory Objectives guide any judicial examination of this subject.
11 ABA TASK FORCE ON THE FUTURE OF LEGAL EDUCATION, REPORT AND RECOMMENDATIONS 3 (2014),
https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/report_and_reco
mmendations_of_aba_task_force.pdf [hereinafter LEGAL EDUCATION REPORT].
12 AM. BAR ASS’N COMM’N ON THE FUTURE OF LEGAL SERVS., REPORT ON THE FUTURE OF LEGAL SERVICES
IN THE UNITED STATES 6 (2016), supra at 40-41.
13 Id. Since the Commission’s report was written, Utah has created Licensed Paralegal Practitioners
starting in 2019 and New Mexico is considering the creation of Limited Licensed Legal Technicians that
are similar to those in Washington state.

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
The Resolution takes a similar approach and merely encourages U.S. jurisdictions to
consider this kind of regulatory reform.
B.
Experimenting with Variations to Rule 5.4
Rule 5.4 of the Model Rules of Professional Conduct generally prohibits
lawyers from partnering and sharing fees with anyone who is not a lawyer.
This prohibition impedes the development of innovative legal service
delivery models,14 especially those that require the active involvement of
other kinds of professionals, such as technologists, or that need substantial
outside capital to succeed. Modifying Rule 5.4 in ways that do not sacrifice
client and consumer protection and that permit other professionals to
participate more fully in the development of impactful solutions is another
tool that can be available for those who wish to use it.
The growing experience around the world with such arrangements –
often called alternative business structures (ABS) – suggests that there is a
great deal to gain by experimentation in this area.15 For this reason, several
states recently adopted or are proposing significant liberalization of their
versions of Model Rule 5.4.16
The ABA Commission on the Future of Legal Services called for this
kind of review. In its final report, the Commission recommended “continued
exploration” of reforms in this area so that “evidence and data regarding the
risks and benefits associated with” ABS can be developed and assessed.
The benefits from such reforms are compellingly stated in a recent
book by United States Supreme Court Justice Neil Gorsuch:
All else being equal, market participants with greater access to capital can
increase output and lower price. So, for example, optometry, dental, and tax
preparation services are no doubt cheaper and more ubiquitous today thanks to
the infusion of capital from investors outside those professions. Indeed,
consumers can often now find all these services (and more) in their local
“superstores.” Yet Rule 5.4 of the ABA’s Model Rules of Professional Conduct —
adopted by most states — prohibits nonlawyers from obtaining “any interest” in a
law firm. So while consumers may obtain basic medical and accounting services
cheaply and conveniently in and thanks to (say) Walmart, they can’t secure
similar assistance with a will or a landlord-tenant problem. With a restricted
capital base (limited to equity and debt of individual partners), the output of legal
services is restricted and the price raised above competitive levels….
Notably, the United Kingdom has permitted multidisciplinary firms and nonlawyer
14 WILLIAM HENDERSON, STATE BAR OF CAL., LEGAL SERVICES LANDSCAPE REPORT (2018),
http://board.calbar.ca.gov/docs/agendaItem/Public/agendaitem1000022382.pdf.
15 Id.
16 See ABA CTR. FOR INNOVATION, LEGAL INNOVATION REGULATORY SURVEY,
http://legalinnovationregulatorysurvey.info/ (last visited Nov. 4, 2019).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
investment since 2007. In the first two years of the program, 386 so-called
“alternative business structures” (ABSs) were established. Six years into the
experiment, the Solicitors Regulatory Authority analyzed ABSs and found that
while these entities accounted for only 3 percent of all law firms, they had
captured 20 percent of consumer and mental health work and nearly 33 percent
of the personal injury market — suggesting that ABSs were indeed serving the
needs of the poor and middle class, not just or even primarily the wealthy.
Notably, too, almost one-third of ABSs were new participants in the legal services
market, thus increasing supply and presumably decreasing price. ABSs also
reached customers online at far greater rates than traditional firms — over 90
percent of ABSs were found to possess an online presence versus roughly 50
percent of traditional firms, again suggesting an increased focus on reaching
individual consumers. Given the success of this program, it’s no surprise that
some U.S. jurisdictions have appointed committees to study reforms along just
these lines.17
On several occasions, the ABA has considered and rejected amendments to Model
Rule 5.4 that would have permitted some form of ABS. The primary argument against
such changes was that they would have jeopardized a lawyer’s professional
independence. These concerns, however, fail to recognize that lawyers already exercise
professional independence in conceptually similar situations. 18
Another reason to be skeptical of the concern about professional independence is that
there is no evidence of public harm in the increasing number of the countries that now
permit lawyers to practice in some form of ABS. 19 The ABA Commission on the Future of
Legal Services made a similar observation in its final report:
The Commission’s views [calling for continued exploration of reforms in this area]
17 NEIL M. GORSUCH, A REPUBLIC IF YOU CAN KEEP IT 258-60 (2019).
18 Justice Gorsuch explains:
For example, we permit third parties (e.g., insurance companies) to pay for an insured’s
legal services but restrict their ability to interfere with the attorney-client relationship. We allow inhouse counsel to work for corporations where they must answer to executives but require them
sometimes to make noisy withdrawals. And we increasingly permit law firms to manage client and
personal financial conflicts by screening affected lawyers rather than by banning the firm from
representing a client. Of course, in each of these cases lawyers stand to benefit from rules that
permit an engagement that might otherwise be forbidden while here, by contrast, they may stand
to lose financially. But surely it shouldn’t be the case that we will forgo or lift outright bans in favor
of more carefully tailored rules only when it’s in our financial interest.
Id.at 260.
19 ABA COMM’N ON THE FUTURE OF LEGAL SERVS., ISSUES PAPER REGARDING ALTERNATIVE BUSINESS
STRUCTURES 11 (2016),
https://www.americanbar.org/content/dam/aba/images/office_president/alternative_business_issues_pape
r.pdf; LEGAL SERVS. BD., TECHNOLOGY AND INNOVATION IN LEGAL SERVICES 2018,
https://www.legalservicesboard.org.uk/research/technology-and-innovation-in-legal-services-2018 (last
visited Nov. 4, 2019).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
were informed by the emerging empirical studies of ABS. Those studies reveal
no evidence that the introduction of ABS has resulted in a deterioration of
lawyers’ ethics or professional independence or caused harm to clients and
consumers. In its 2014 Consumer Impact Report, the UK Legal Consumer Panel
concluded that “the dire predictions about a collapse in ethics and reduction in
access to justice as a result of ABS have not materialised.” Australia also has not
experienced an increase in complaints against lawyers based upon their
involvement in an ABS.20
Despite the limited risks associated with liberalizing Rule 5.4 to allow lawyers to practice
in settings outside the traditional law firm or to seek equity funding from the capital
markets and the potential innovations that might accompany it, it is also clear that there
is not yet enough data to know what the “model” approach to this subject should be or
what effect ABS will have on addressing the access to justice crisis. For this reason, the
resolution does not propose a specific change to Model Rule 5.4 and instead merely
encourages jurisdictions to try new approaches so that we can learn from them and
assess their impact.
C.
New Approaches to the Unauthorized Practice of Law
The resolution also encourages U.S. jurisdictions to develop more permissive
approaches to the unauthorized practice of law (UPL). U.S. jurisdictions often define
UPL broadly or in such an ambiguous way that prospective innovators do not want to
risk developing new services and face allegations that they are engaging in UPL.
Appropriate and careful liberalization of UPL provisions can change this dynamic and
encourage more innovation.
With appropriate re-regulation, the risks from more permissive UPL rules are
small. For example, in the United Kingdom, rather than trying to define the practice of
law, the Legal Services Act of 2007 provides that anyone can perform law-related
activities unless those activities are specifically “reserved” for authorized professionals.
That is, the burden is on the profession to identify the specific areas of legal
services that only authorized professionals should be permitted to perform. There is no
evidence of harm in the U.K. from such an approach relative to the much more
restrictive approach in the U.S., where the definition of UPL tends to be so vague that it
covers a range of services that could be safely performed by professionals other than
lawyers.21
Recognizing the problems with existing approaches to UPL and the low risks
from careful step-by-step liberalization of existing policies, several U.S. jurisdictions
have begun to experiment in this area. For example, Utah has developed a so-called
20 See LEGAL EDUCATION REPORT, supra note 11, at 42.
21 Deborah L. Rhode, What We Know and Need to Know About the Delivery of Legal Services by
Nonlawyers, 67 S. C. L. REV. 429, 431-33 (2016).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
“regulatory sandbox” that will allow new kinds of legal services providers to operate on a
pilot basis without concerns that they will be accused of UPL. 22 Other jurisdictions are
seeking to expressly recognize that online legal document providers are not engaged in
the unauthorized practice of law in exchange for modest regulation or registration
requirements.23
These developments are still in their infancy in the U.S., so as with other
regulatory reforms, it is not possible to identify a model approach. (Indeed, such efforts
in the UPL particular context may raise antitrust concerns.) 24 The point of the resolution
is to encourage U.S. jurisdictions to consider regulatory innovations that foster new
ways to deliver effective legal services and have the potential to improve the
accessibility, affordability, and quality of those services while preserving core
protections.25
IV.

Data Should be Collected and Analyzed

The final part of the resolution calls for the collection and assessment of data
regarding regulatory innovations, both before and after the adoption of any innovations,
to ensure that changes are data driven and in the interests of the public. The collection
of such data is critical if the legal profession is going to make reasoned and informed
judgments about how to regulate the delivery of legal services in the future and how to
address the public’s growing unmet legal needs. We need to experiment with different
approaches, analyze which methods are most effective, and determine which kinds of
regulatory innovations best provide the widest access to legal services, provide
continuing and necessary protections for those in need of legal services, and best serve
the public interest.
V.

Conclusion

Justice Louis Brandeis once wrote that “[i]t is one of the happy incidents of the
federal system that a single courageous State may, if its citizens choose, serve as a
laboratory; and try novel social and economic experiments without risk to the rest of the
country.”26 The resolution calls for precisely this kind of courageous experimentation. In

22 Press Release, Utah Courts, Utah Supreme Court Adopts Groundbreaking Changes to Legal Serv.
Regulation (August 29, 2019), https://www.utcourts.gov/utc/news/2019/08/29/utah-supreme-court-adoptsgroundbreaking-changes-to-legal-service-regulation/.
23 Jim Ash, Board Recommends Voluntary Registration Program for Online Legal Service Providers, FLA.
BAR NEWS (Sept. 25, 2019), https://www.floridabar.org/the-florida-bar-news/board-recommends-voluntaryregistration-program-for-online-legal-service-providers/.
24 ABA CTR. FOR PROF’L RESPONSIBILITY, FTC Letter Opinions on the Unlicensed Practice of Law (June
23, 2016),
https://www.americanbar.org/groups/professional_responsibility/resources/client_protection/ftc/.
25 See supra note 9.
26 New States Ice Co. v. Liebmann, 285 U.S. 262, 311 (1932).

 The views expressed herein represent the opinions of the authors. They have
not been approved by the House of Delegates or the Board of Governors of
the American Bar Association and, accordingly, should not be construed as
representing the position of the Association or any of its entities.
light of the severe access to justice crisis in the United States, the continued reliance on
existing regulatory approaches is not a viable or responsible option.
Respectfully submitted,
Daniel B. Rodriguez
Chair, Center for Innovation
February 2020