LIV President's Blog 2012

LIV President's Blog 2012

Michael Holcroft, LIV President 2012 on the latest issues and topics. Read and comment.

Supreme Court considers what is “Ordinary legal work”

Supreme Court considers what is “Ordinary legal work”

The Supreme Court of Victoria has, again, been asked to consider what constitutes “legal work”. In Dr Claire Noone, Director of Consumer Affairs Victoria v Peter Mericka & Ors [2012] VSC 101, handed down this week,  the court looked at issues including whether a legal practitioner was exempted from being required to hold a real estate licence when carrying on some aspects of work usually undertaken by Real  Estate Agents.

What are considered ‘ordinary functions’ of a legal practitioner?
In considering whether the (limited) solicitor exemption under the Estate Agents Act 1980 (Vic) [“the Act”], applied to aspects of the sale of real estate, the Court examined Section 5 (2) (e) of the Act.

S5 (2) (e) exempts conduct “for the purpose only of carrying out the ordinary functions of an Australian legal practitioner”.

Sifris J, relying on precedent from Cornall v Nagle (2 ) recited “…the giving of legal advice, at least as a part of a course of conduct and for reward, can properly be said to lie at or near the very centre of the practice of law…” and from  Leary v Federal Commissioner of Taxation (3) in part

“…whether his services are sought with respect to the operation of taxing statutes, the provisions of contract, charges under the criminal law or any other of the varied fields of professional concern…”.

His Honour found that the defendants’ activities did fall within the bounds of the Act, and that the activities went beyond ”… the ordinary functions of an Australian legal practitioner”.

Practitioners need to consider what parts of conveyancing practice represent “ordinary functions” of a legal practitioner. 

What constitutes legal work a vexed question
It is also, perhaps, timely to remind our Real Estate Agent friends, that they are not entitled to advise in relation to contracts, draft special conditions or do more than “fill in the blanks” of the joint REIV / LIV contract for sale of land.

Tax agents and accountants, likewise, should be reminded that they are not be permitted to provide advice of the impact of tax legislation in their role as tax advisors as this would seem to be legal practice as defined in the cases above.

The exact nature of what constitutes legal work has been a vexed question for some time, and we are still without a definitive judicial ruling.

Whilst we remain without any comprehensive definition of what constitutes legal work, we should stand resolute against non-lawyers undertaking what we know to be legal work.

Lawyers who undertake conveyancing work are encouraged to read the full judgment in this case.

I welcome your comments on this issue.

 

 
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Comments

Comments
Christian
To whom it may concern;
My apologies for the late response. I found this article particularly interesting. Since wide spread industry feedback, Australian training/qualifications in legal services for paralegals has evolved. A new course of which I am a graduate was created to satisfy a need for career paralegals uninterested in a career in legal practice.


http://training.gov.au/Training/Details/BSB50110

The issue this sought to address was the turnover of paralegals in the industry, especially for small firms, who hired law students or graduates keen to get their foot in the door. The industry specifically requested a legal qualification which would allow those interested in assisting legal practice and giving general compliance advice, without the need for a legal qualification.

The concept, as told to me, was that this new breed of paralegals would one day evolve into being able to offer general legal advice, and not personal legal advice, similar to those who are within the financial services industry:

Tier 2 financial advice (General advice)
Mortgage brokers
Insurance sales/brokering
General financial advice and information on financial products or strategies

Tier 1 financial advice (Personal advice)
Financial planning
Stock/Managed investment advice
Retirement advice

http://www.asic.gov.au/asic/asic.nsf/byheadline/CP-183-Giving-factual-information-general-advice-and-personal-advice--submissions?openDocument

Sadly their is no distinction or definition of general or broad legal advice or opinion, as distinct from personal or tailored legal advice or opinion. Further, the term paralegal is very grey and is not adequately regulated by each of the legal service bodies. Their is little in the way of recognition or minimum qualification, such as can be found within the financial advisory business or tax versus BAS agents under the Tax Practitioners Board. I urge strenuously that this be looked at as part of Legal Professional reform:

http://www.ag.gov.au/Consultations/Pages/NationalLegalProfessionalReform.aspx

Regards
20/12/2012 9:52:52 AM

Peter Mericka
The case does draw attention to other issues that have never been properly considered by ILPs or those who regulate them.

For example, the Conveyancers Act rendered the employment of conveyancing paralegals by ILPs as problematic because all conveyancing work in an ILP must be completed by an Australian Legal Practitioner, and not by a paralegal.

On the other hand, an incorporated conveyancing business or a sole practitioner is not similarly constrained.

What advice does the LIV and the LPLC offer to ILPs and their directors regarding work involving conveyancing and negotiating of leases and sales and purchases of real estate and businesses?
7/04/2012 8:52:54 AM

Keith Harvey
I wonder if the statutory carve out in the FSRA for lawyers still applies to ILP's?

Similarly, does the lawyer's carve out under the Tax Administration Act still apply to ILP's?

How many other examples exist in regard to problems for ILP's? Who is going to work on these issues?
6/04/2012 12:04:32 AM

Peter Mericka
Michael, I should have also have pointed out that the MERICKA case tells us that even if the Legal Practitioner Director, as an individual, enjoys an exemption, it does not follow that the ILP is not in breach.

As director of my ILP, I have been found to have aided and abetted my ILP in its breach of the Act.

Sifris J found,

"Further, given that Mr Mericka is and, at all relevant times, has been the sole director, secretary and (directly or indirectly) the sole shareholder of Lawyers Real Estate and SLOD, I find that he knowingly authorised or permitted the contravention of s12 of the Estate Agents Act by those companies."
4/04/2012 5:12:02 AM

Peter Mericka
Michael, the exemption is not total, that's what the MERICKA case is telling us.

If the delivery of services becomes ongoing and systematic it can morph into a real estate business.

For example, if a lawyer is asked by a client to negotiate a real estate contract with another practitioner or real estate agent, particularly if it includes discussion on price, the risk grows as the frequency of service delivery grows.

Thus, if a lawyer becomes popular, and has clients referred to him/her for this purpose, the legal practice may become a real estate business. This is particularly so if the legal practitioner advertises the service.
3/04/2012 4:05:21 PM

Michael Holcroft
On my reading of the decision, individual lawyers within an ILP would still be classified as Australian Legal Practitioners (as they have Practising Certificates). The status of para-legals is less clear.
3/04/2012 1:33:16 PM

Peter Mericka
ANY lawyer who has incorporated their legal practice is now in strife if they negotiate purchases or sales of real estate on behalf of their clients as a part of their business as a lawyer.

Note that the definition is not just about sales, but also purchases.

As an aside (it was not mentioned in my matter), but a practitioner who previously employed paralegals to complete conveyancing work is also in strife if they continue this practice after incorporation, as the exemption in the Conveyancers Act for ILPs only applies where "if the conveyancing work is carried out on its
behalf by an Australian legal practitioner". However, an incorporated conveyancing business does not appear to be similarly constrained.

So, even where ILPs are actually considered in legislation, they still have less standing than an individual.

I am discovering the hard way that ILPs have major shortcomings!
3/04/2012 11:46:37 AM

Philip Argy
It is certainly an odd conclusion that "person" does not include a company. But also the conclusion that the activities of real estate agents are activities in which lawyers do not "ordinarily" engage. This depends on the level of abstraction, of course, so that negotiating agreements is normal if it in the generality but apparently not if the agreements are invariably for the purchase or sale of real property. Similarly with the other 'trappings' of an estate agent, that could quite easily have been reduced to their generic description to see that they were indeed activties in which lawyers ordinarily engage! How different is a house from a business in terms of the activities in which lawyers ordinarily engage?
3/04/2012 11:38:59 AM

Michael Holcroft
I was surprised with that part of the decision that said an ILP was not an Aust Legal Practitioner for the purposes of the Real Estate Act. The LIV is reviewing the decision and will consider our response at a Council level.
3/04/2012 11:06:43 AM

Philip Argy
There is no public policy reason for requiring a regulated professional such as a solicitor to be double regulated. If Mericka appeals LIV should intervene to support him, to ensure that solicitors who want to be innovative in servicing their clients are not constrained.
3/04/2012 7:29:30 AM

Peter Mericka
The MERICKA decision has raised a number of issues for lawyers. Here's just one of them:

When my practice was incorporated under the Legal Practice Act my ILP was a legal practitioner, and exempt under the Estate Agents Act.

This exemption was lost when the Legal Profession Act was introduced.

Quaere: Was this an oversight by Parliament? Or was it intended that ILPs should enjoy an exemption one moment and become liable the next?

Why did the LIV or the LPLC not warn practitioners of this problem?
2/04/2012 2:20:39 PM

Peter Mericka
Will everyone please read the judgement CAREFULLY! You will see that there is no suggestion at all that a lawyer cannot perform any of the functions performed by me or my firm. The court has simply found that if certain things are done in an ongoing and systematic manner then a legal business can assume the characteristics of a real estate business. For example, placing an advertisement is not beyond the capacity or competence of a lawyer, but if done on an ongoing and systematic basis then the activity can cease to be a function that can be performed by a lawyer.

Compare this with the giving of financial advice for which an AFS licence is required. In the latter case it can be clearly said that the lawyer should refer the client to an AFS licence holder, who is more qualified to advise and to protect the client's financial interests.

However, the issue is not quite as clear if a lawyer who regularly represent purchasers in negotiations to purchase residential real estate is, after having provided such services in an ongoing and systematic basis, suddenly required to refer all further clients to the young real estate sales consultant with blonde tips and a Certificate IV in Real Estate Practice.
31/03/2012 5:10:09 PM

Michael Holcroft
Dear Henry,
I cannot give you legal advice in this forum. I do suggest that you read the case carefully, it speaks of what is “legal advice” and what may fall outside the “normal legal practice”.

I am prepared to suggest that if you have two separate business running (one as lawyer and one as Estate Agent), and presumably with two ABNs, that I would expect each entity to render its own invoice.
30/03/2012 6:20:50 PM

Gavin Moodie
The defendant solicitor had incorporated his practice as 'Lawyers Real Estate' which fairly described his practice, so it wasn't a strong case to argue the extent of legal work.
30/03/2012 2:04:02 PM

Henry Burstyner
Dear Sir,
I have been (and still am) a Licensed Real Estate Agent since 1972 and have been (and still am) a registered Victorian Legal Practiitoner since 1982. ( I don't know if there there are any others who are both Licensed Real Estate Agents as well as being Licensed Legal Practitioners in Victoria )
I conduct separate and different business names but I don't conduct a Real Estate Trust Account. however I have consulted as a Real Estate Agent with respect to Real Estate matters and have charged consultation fees for such consultations as a Real Estate Agent.

Furthermore as a Legal Practitioner I of course I
have acted with respect to numerous conveyancing matters over the last 32 odd years and on these occasions have charged legal scale conveyancing fees.

Is it your understanding that when a matter requires me to act in such a way so as to require me to wear two hats, I am obliged to try and issue Two separate Tax Invoices, one for any Real Estate Advice and or consultation and a second for any Legal Advice and or consultation.

Yours faithfully
Henry Burstyner
30/03/2012 1:14:03 PM

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