Legal Ethics Opinion No. 1441 Acquiring an Interest in Client's Matter--Conflict of Interest: Attorney Making Loans to Finance Company Which Makes Loans to Attorney's Personal Injury Clients You have presented a hypothetical situation in which an attorney (A), who represents personal injury plaintiffs, occasionally refers clients to Corporation X (X) which is a Virginia corporation engaged in extending credit to injured persons while they are awaiting resolution of their tort claims to recover damages for their injuries. The credit line is evidenced by a personal note from the plaintiff secured by an assignment of the proceeds from the claim and is due and payable in full at the time of settlement. The plaintiff's attorney does not guarantee, nor obligate himself or his firm in any way, for repayment of the credit extended to his client, but he is obligated, however, to acknowledge the assignment and disburse to X the funds to repay the note from the proceeds of the settlement. You have additionally indicated that plaintiff's attorney may be asked to oversee the execution by his client of the credit documents from X. Attorney A also furnishes information to X relative to the claim, with his client's authorization, which information later becomes the basis for the credit determination. Attorney A receives no fee or other compensation from X for these services, nor will he either provide any legal advice or services to X or have any input into X's decision with regard to the establishment of the credit limit. A desires to lend money to X and you have indicated that no portion of those funds being loaned to X by A will be earmarked for A's clients, nor will A have any influence upon X's decision as to how any of the funds are utilized. Furthermore, none of X's receivables from A's clients will be assigned to A as security for his loan nor will A receive any corporate stock or other form of ownership interest in X. You indicate that the only benefit from the loan which A will receive is the payment of interest which will be equal to that which X would pay to any other lender under similar circumstances. Finally, A will not be a member of X's board of directors or advisory board. Finally, you indicate that all such exclusions from any direct or indirect management, control, or influence over the operations and business decisions of X will also extend to A's family, other relatives, and members and employees of his firm. You have asked the committee to opine whether, under the facts of the inquiry, it would be proper for A to make such a loan to X and whether such a loan to X made by A's spouse or A's employees would be proper as to A. The appropriate and controlling Disciplinary Rules related to your inquiry are DR 5-l03(A) which mandates that a lawyer shall not acquire a proprietary interest in the cause of action or subject matter of litigation he is conducting for a client; DR 5-103(B), which provides that a lawyer representing a client in contemplated or pending litigation shall not advance or guarantee financial assistance to his client, except that the lawyer may advance or guarantee the expenses of litigation, provided the client remains ultimately liable for such expenses; and DR 5-l0l(A), which precludes a lawyer from accepting employment, absent the consent of his client after full disclosure, if the exercise of his professional judgment on behalf of his client may be affected by his own financial, business, property, or personal interests. The committee has previously opined that an attorney may persuade a finance company to loan funds to the attorney's personal injury client and may honor the finance company's lien on the client's settlement proceeds, as long as the attorney did not guarantee or cosign the loan. See LEO #ll55. The committee has also opined that where an attorney has persuaded a finance company to loan funds to the attorney's personal injury client, it is not improper for the attorney to receive completed but unsigned loan documents, supervise his client's execution of the documents, and then return the documents to the finance company. See LEO #1379. The committee believes that A's loan to X is thus a means by which A has provided indirectly what he may not provide directly, i.e., financial assistance to his client in connection with litigation. Furthermore, the committee views such an arrangement as a means by which A has also acquired indirectly what he may not acquire directly, i.e., an interest in the client's litigation matter. Thus, the committee is of the opinion that, despite the controls you propose, it would be improper and violative of Disciplinary Rules 5-l03(A) and (B) and 5-l0l(A) for A, his spouse or employee, to make a loan to X Corporation unless X agrees to make no loans to A's clients during A's representations of those individuals or entities. Committee Opinion January 6, 1992
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