Fwd: Two notice-and-comment letters for signature -- CLE requirement, and Power of Attorney nuisance rules

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David Boundy

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Feb 17, 2021, 6:06:53 PM2/17/21
to pate...@googlegroups.com

Dear listmates:



Two notice-and-comment letters request your signature.  (The PTO was very busy publishing notices in late December and early January.)  Please sign, and pass this email on to your colleagues.



Topic 1: The PTO’s proposed CLE rules.  For the PTO’s proposed CLE rules, what would you estimate as total costs for the following:

-- Time browsing CLE catalogs and sifting through emails from CLE providers to find relevant courses

-- Registering for the courses and paying for them

-- Recordkeeping to maintain attendance certificates

-- Travel to live courses

-- Attending the courses

-- Program cost and tuition

-- Assembling and reporting the attendance certificates at the time of filling out the CLE certification of the PTO’s proposed biennial statement

-- for CLE providers, getting approval from the PTO, while the PTO competes by offering its own CLE for free

Just take a guess.  (A group formed a consensus estimate of around $100 million per year, as the increment over the cost of complying with state mandatory CLE.)

What does the PTO estimate?

ZERO.

So, this comment letter gives revised estimates in response to this notice.  This letter is due Monday 2/22, so I need your signature no later than noon (eastern) on Monday.  The letter expresses no objection to CLE in principle; the objection is to the serial avoidance of the procedures required for rulemaking, and the cost-benefit balancing required by multiple laws.  This letter only complains about procedural failure and the PTO’s pattern of creating huge costs for applicants by mere failure to ask the questions required by law.  The letter takes no position on whether CLE is or is not a good idea.

The letter for your review is at https://drive.google.com/file/d/1-17DJuWGx80RkvEAnrhsnafl0y8co-5z  

Please add your name to the signature list at  https://docs.google.com/spreadsheets/d/1FhDxzrUCRzjjY1lL6dEBq1KQnoiaqP3bbohjPqY6TEg

Suggestions/corrections to me at DavidBo...@gmail.com

 

Topic 2: Powers of Attorney.  The PTO estimates that Powers of Attorney take 3 minutes each.  The PTO has changed the rules substantially, multiple times over the last decade, each time increasing the technicalities and burden, without accounting for the costs of complexity.  A comment letter on Powers of Attorney is at  https://drive.google.com/file/d/1_HoZVqB8Ek8WFJurLKaaJqot0mwZmqEH   This letter gives corrected estimates, and urges the PTO to fix a bunch of things that create $100 million/year in unnecessary costs.

Please add your name at  https://docs.google.com/spreadsheets/d/1i5vmWQR0qZOQPfuj3OstyXqP3oB9veVSCk5qsJksHqE/edit?usp=sharing_eil&ts=602991c5

 

Thank you all.


David



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