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The California Application for Registered In-House Counsel (RIHC) is an essential document for out-of-state attorneys seeking to serve as in-house legal advisors within California. Managed by the State Bar of California Office of Admissions under its Multijurisdictional Practice (MJP) Program, this application facilitates attorneys who are already in good standing in at least one U.S. jurisdiction to practice within the confines of their employment at a qualifying institution, without the need to pass the California Bar Examination. The process involves meticulous documentation, including personal and employment information, a detailed attorney declaration, and the declaration of the qualifying institution proving the attorney's and the institution's eligibility under the program's specific requirements. Moreover, applicants are expected to adhere to stringent moral and professional standards, mirroring those expected of California's bar members, as their practice is strictly limited to the entity that employs them and prohibits any personal or individual legal representation outside of this context. The submission of this application, accompanied by a substantial fee, marks the beginning of a rigorous vetting process, ensuring that only those who fulfill the high standards set forth by the California Rules of Court, rule 9.46 and the Registered In-House Counsel Program Rules, are granted the privilege to practice law within the state's specific regulatory framework.

Document Example

The State Bar of California

Office of Admissions – MJP Program

845 S. Figueroa Street, Los Angeles, CA 90017-2515 (213) 765-1500

Out-of-State Attorney Registered In-House Counsel Program Application

You must register as an Attorney Applicant with the State Bar’s Office of Admissions prior to submitting this application.

FOR OFFICIAL USE ONLY

$_______

No Payment

9.46

ID #: ___________________________

File #: __________________________

Registrant Information:

Type or Print Clearly

Last Name:

 

First Name:

 

Middle Name:

Date of Employment as an In-House Counsel:

Employer (Institution): *Address:

City:

 

 

 

 

State:

 

Zip:

 

Phone:

 

Fax:

 

 

E-mail:

 

 

 

Date of Birth:

 

 

 

Place of Birth:

 

 

 

Undergraduate School:

 

 

 

 

City, State:

 

 

 

Law School:

 

 

 

 

City, State:

 

 

 

*As a registered In-House Counsel, your address of record is public information subject to disclosure upon request and also posted on the State Bar’s Web site. List your employer’s California office address.

Employer Contact:

Phone:Fax:E-mail:

Application Attachments:

A: Attorney Declaration

B: Declaration of Qualifying Institution

C: Admissions/Standing List

The Determination of Moral Character (MC) application must be completed and paid for online. A printed hard copy of the online MC application must be submitted with the MJP application.

$635 Application Fee

Current original Certificate of Good Standing from all out-of-state jurisdictions.

RIHC Application 2017_R

Page 1 of 4

Acceptable forms of payment: credit card authorization form, cashier’s check, travelers’ check or money order made payable to “State Bar of California.”

Personal checks will not be accepted.

MAIL TO:

The State Bar of California

Office of Admissions

MJP Program

845 S. Figueroa Street

Los Angeles, CA 90017-2515

The State Bar of California

Office of Admissions – MJP Program

845 S. Figueroa Street, Los Angeles, CA 90017-2515 (213) 765-1500

Out-of-State Attorney Registered In-House Counsel Program Application

Attachment A – Attorney Declaration

a.I am currently a member in good standing of and eligible to practice law in at least one jurisdiction in the United States.

b.I am not suspended, disbarred or resigned with charges pending from any professional occupational disciplinary agency or licensing board.

c.I agree to be subject to the disciplinary authority of The Supreme Court of California and The State Bar of California with respect to the law of The State of California governing the conduct of attorneys, to the same extent as a member of The State Bar of California.

d.As Registered In-House Counsel, I will practice law for a SINGLE Qualifying Institution in California which employs me.

e.I understand that I may qualify to simultaneously practice law under the Registered Legal Services Attorney Program.

f.I currently reside in California.

g.I will not provide personal or individual representation to any customers, shareholders, owners, partners, officers, employees, servants, or agents of the Qualifying Institution.

h.I will not make court appearances in California state courts or engage in any other activities for which Pro Hac Vice admission is required.

i.I agree that in my first year of practice under the Registered In-House Counsel Program, I will satisfy all of the Minimum Continuing Legal Education requirements that members of The State Bar of California must complete every 3 years and thereafter satisfy the Minimum Continuing Legal Education Requirements applicable to all members of The State Bar of California.

j.I will notify The State Bar of California in writing within 30 days of a change in any information provided in my application, including my address, employment at a qualifying institution, or eligibility to practice law in another jurisdiction. Eligibility would be changed by a suspension, resignation with or without charges pending, disbarment, or its functional equivalent.

k.I will provide The State Bar of California with a forwarding address to which any notices or papers may be mailed within 30 days of cessation of employment by the Qualifying Institution.

l.I am aware that filing a certificate containing false information or otherwise failing to comply with the standards of professional conduct required of members of The State Bar of California or the rules governing Registered In-House Counsel will subject me to the disciplinary jurisdiction of The State Bar of California.

I declare under penalty of perjury under the laws of The State of California that the foregoing application and any attachments to it are true and correct.

Date:

 

Print Name:

 

 

Signature:

RIHC Application 2017_R

Page 2 of 4

The State Bar of California

Office of Admissions – MJP Program

845 S. Figueroa Street, Los Angeles, CA 90017-2515 (213) 765-1500

Out-of-State Attorney Registered In-House Counsel Program Application Attachment B – Declaration of Qualifying Institution

Eligibility Status: Type or Print Clearly

I am a(n):

Officer

of Institution Name:

Director

General Counsel

Name (Individual Referenced Above):

 

 

 

 

 

Title:

 

Address:

 

 

 

 

 

 

 

 

 

 

 

 

City:

 

 

 

 

 

State:

 

 

 

Zip:

 

Phone:

 

Fax:

 

 

E-mail:

 

 

 

 

Applicant Name:

 

 

 

 

is employed as In-House Counsel for the

institution reference above.

 

 

 

 

 

 

 

 

 

 

 

The Effective Date of Applicant’s Employment:

Employer Contact:

Phone:Fax:E-mail:

The institution referenced above is a Qualifying Institution which is defined by California Rules of Court, rule

9.46as a corporation, a partnership, an association, or other legal entity and is not a government agency and DOES NOT provide legal services to others.

This institution employs at least 10 full-time employees in the State of California.

(# of employees:

 

)

OR

This institution employs the following California attorney who is an active member in good standing of the State Bar of California.

Name:

 

Bar Number:

I will notify the State Bar within 30 days if the eligibility status listed above changes or if the applicant’s employment ceases.

To the best of my knowledge and after reasonable inquiry, I believe that the applicant is of good moral character and qualifies for registration under California Rules of Court, rule 9.46 and the Registered In- House Counsel Program Rules.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Date:

Print Name:

 

 

Signature:

RIHC Application 2017_R

Page 3 of 4

 

 

The State Bar of California

Office of Admissions – MJP Program

845 S. Figueroa Street, Los Angeles, CA 90017-2515 (213) 765-1500

Out-of-State Attorney Registered In-House Counsel Program Application

Attachment C – Admissions/Standing List

Date:

 

 

 

Print Name:

 

 

 

 

 

 

 

 

 

Date

Member

State/Court

 

Status

Prior Discipline Record

Admitted

Number

(e.g., Ohio or USDC or 9th Circuit)

 

(e.g., Active)

If ‘Yes’ Attached Details

 

 

 

 

 

 

 

Yes

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Yes

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Yes

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Yes

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Yes

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Yes

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Check here if additional sheets listing details of prior record of discipline are attached.

RIHC Application 2017_R

Page 4 of 4

Form Breakdown

Fact Name Detail
Form Purpose The form is for out-of-state attorneys applying to the Registered In-House Counsel Program in California.
Application Requirement Attorneys must register with the State Bar's Office of Admissions before submitting the application.
Application Fees The application process requires a $550 Application Fee and a $500 Moral Character Determination Fee.
Address Disclosure The address of registered In-House Counsel is public and will be posted on the State Bar's website.
Practice Restrictions Registered In-House Counsel can only practice for their employing Qualifying Institution and cannot make court appearances in California state courts.
MCLE Requirements In their first year, registered In-House Counsel must meet the Minimum Continuing Legal Education requirements that California attorneys complete every 3 years.
Eligibility Confirmation Applicants must declare they are in good standing and eligible to practice law in at least one U.S. jurisdiction.
Payment Methods Acceptable payment methods include cashier's checks, travelers’ checks, or money orders, but personal checks are not accepted.
Information Update Applicants must notify the State Bar of California within 30 days of any changes to their information, including address or employment status.
Disciplinary Authority Applicants agree to be subject to the disciplinary authority of The Supreme Court of California and The State Bar of California as if they were members.
Governing Law The application is governed by the laws of the State of California.

How to Write California Application Registered In Counsel

Successfully completing the California Application Registered In-House Counsel form is a significant step for out-of-state attorneys seeking to practice in-house law in California. Gathering all necessary information and understanding the required steps beforehand can streamline the process and ensure accuracy in your application. The following instructions are designed to make the application process as clear and straightforward as possible.

  1. Begin by registering as an Attorney Applicant with the State Bar’s Office of Admissions if you have not already done so.
  2. Ensure you type or print clearly when filling out the form to avoid any misunderstandings or delays in processing.
  3. Under "Registrant Information," fill in your last name, first name, and middle name.
  4. Provide the date of employment as an In-House Counsel and fill in your employer's information, including the institution's name, address, city, state, zip, phone, fax, and e-mail.
  5. Enter your date of birth and place of birth in the designated fields.
  6. Indicate the information about your education by specifying your undergraduate and law schools, including the city and state for each.
  7. Under "Employer Contact," input the phone, fax, and e-mail of a contact person at your institution.
  8. Move on to the application attachments required:
    • Attachment A: Attorney Declaration. Read and affirm the declarations provided, acknowledging your understanding and agreement.
    • Attachment B: Declaration of Qualifying Institution. Have an officer, director, or general counsel of your institution complete this section to verify the institution qualifies under rule 9.46 and your employment status.
    • Attachment C: Admissions/Standing List. List all jurisdictions where you are admitted to practice law, your status in those jurisdictions, and any prior discipline records.
  9. Enclose the Application for Determination of Moral Character in a sealed envelope, along with the Original Certificate of Good Standing.
  10. Prepare a payment of $550 for the Application Fee and a $500 Moral Character Determination Fee. Make a cashier's check, travelers’ check, or money order payable to "State Bar of California." Note that personal checks are not accepted, but you may pay both fees with one check.
  11. Review your application thoroughly to ensure all information is accurate and complete. Sign and date the form where required, especially on the Attorney Declaration section.
  12. Mail the completed application, along with all attachments and fees, to The State Bar of California Office of Admissions – MJP Program, 845 S. Figueroa Street, Los Angeles, CA 90017-2515.

Ensuring every part of the application is filled out correctly and all necessary documentation is included will help avoid delays. After submission, your application will be reviewed by the State Bar’s Office of Admissions. Stay informed about the status of your application and be prepared to provide additional information if requested.

Listed Questions and Answers

What is the purpose of the California Application for Registered In-House Counsel?

The California Application for Registered In-House Counsel is designed for attorneys who are licensed outside of California but wish to serve as in-house counsel for a corporation, partnership, association, or other legal entity within the state. This program allows these attorneys to practice law in California without having to pass the California bar exam, provided they meet certain requirements and restrictions outlined by the State Bar of California.

Who is eligible to apply for the Registered In-House Counsel status in California?

Attorneys eligible for this status must be members in good standing of the bar in at least one jurisdiction in the United States and cannot be suspended, disbarred, or resigned with charges pending in any jurisdiction. Applicants must agree to be subject to the disciplinary authority of the Supreme Court of California and the State Bar of California, practice law for a single qualifying institution that employs them, and meet other specified requirements including residing in California and not making court appearances in California state courts.

What are the fees associated with the Registered In-House Counsel application?

The application process requires a $550 application fee and a $500 moral character determination fee. These fees cover the administrative costs of processing the application and assessing the applicant's moral character. Fees must be paid by cashier's check, traveler's check, or money order made payable to the "State Bar of California." Personal checks are not accepted.

What are the continuing education requirements for Registered In-House Counsel?

Registered In-House Counsel must comply with the State Bar of California's Minimum Continuing Legal Education (MCLE) requirements. This involves completing the same amount of MCLE hours that members of the State Bar of California must complete every three years. Additionally, Registered In-House Counsel must satisfy these requirements starting in their first year of practice under this program.

What should an attorney do if their employment or personal information changes after registering as In-House Counsel?

Attorneys are required to notify the State Bar of California in writing within 30 days of any change in their employment status at a qualifying institution, eligibility to practice law in another jurisdiction, or personal information such as address. This ensures the accuracy of the State Bar's records and compliance with the program’s reporting requirements.

What happens if an attorney fails to comply with the standards or provides false information in their application?

An attorney who files an application containing false information or otherwise fails to comply with the professional conduct standards required of members of the State Bar of California, or the rules governing Registered In-House Counsel, will be subject to the disciplinary jurisdiction of the State Bar of California. This can lead to sanctions including but not limited to, suspension or disbarment from the practice of law in California.

Common mistakes

Filling out the California Application for Registered In-House Counsel can be a critical step for attorneys planning to work within a single organization in California. However, mishaps can occur if one is not meticulous. Here are seven common mistakes to watch for:

  1. Not registering as an Attorney Applicant with the State Bar’s Office of Admissions prior to submission. This step is mandatory and must be completed before the application process can officially begin.
  2. Providing inaccurate registrant information, including contact details. The address of record, especially, becomes public information. It's vital to ensure this information is accurate and up-to-date.
  3. Making payment with personal checks. The application specifies acceptable forms of payment, and overlooking this detail can lead to processing delays.
  4. Failing to attach the required Application Attachments (A, B, and C). Each attachment serves a specific purpose, from declaring attorney status to providing evidence of good standing. Missing any could invalidate the application.
  5. Omitting the Application for Determination of Moral Character or not enclosing it in a sealed envelope as instructed. This component is crucial for assessing the candidate’s eligibility from an ethical standpoint.
  6. Incorrectly merging the Application Fee and Moral Character Determination Fee into one payment without following the specified guidelines. While these fees can be combined, doing so improperly can cause confusion.
  7. Neglecting to maintain updated information. Any change, whether it's an address, employment status, or eligibility to practice law in another jurisdiction, must be reported to The State Bar of California within 30 days.

Avoiding these mistakes can help ensure that the application process is smooth and successful. It's about paying close attention to the details and following the instructions carefully. Should there be any confusion or doubt, it's always best to reach out directly to The State Bar of California for guidance.

Documents used along the form

When an out-of-state attorney decides to apply for the California Application Registered In-House Counsel form, it is crucial to be prepared with all necessary documents to ensure a smooth application process. Alongside this form, several other forms and documents are often required to support the application, each serving its own unique purpose in demonstrating the applicant's eligibility and qualifications. Here's a look at some of these vital documents:

  1. Attorney Declaration (Attachment A): This document is a declaration by the attorney applying for in-house counsel registration, affirming their good standing in another jurisdiction, agreement to adhere to the disciplinary authority of California, and commitment to the regulations governing in-house counsel within the state.
  2. Declaration of Qualifying Institution (Attachment B): This is a declaration from the employing institution certifying that it meets the criteria set by California's rules for a qualifying institution and attests to the applicant's employment and good moral character.
  3. Admissions/Standing List (Attachment C): A comprehensive list detailing the applicant's admission status in other jurisdictions, including any prior disciplinary actions. This document helps verify the attorney's legal standing across various states or courts.
  4. Application for Determination of Moral Character: A critical document that assesses the moral character of the applicant, which the California Bar requires to ensure the candidate's fitness to practice law within the state.
  5. Original Certificate of Good Standing: This certificate, sourced from the bar or court of the applicant's current practicing jurisdiction(s), demonstrates that the attorney is currently in good standing and eligible to practice law.
  6. Proof of Payment for Application and Moral Character Fees: Evidence of the submission of the required application and moral character determination fees, confirming the applicant's payment and processing of these fees.
  7. Resume/Curriculum Vitae: While not explicitly listed, a detailed resume or CV may be requested to provide a comprehensive overview of the applicant's professional background, education, and work history.
  8. Proof of Compliance with Minimum Continuing Legal Education (MCLE): Documents showing that the applicant has met any applicable continuing legal education requirements, aligning with California's MCLE standards for legal practice.
  9. Written Employment Agreement: A document evidencing the terms of employment between the in-house counsel applicant and the qualifying institution, detailing the scope of the legal services to be provided.

Each of these documents plays a vital part in the comprehensive review of an out-of-state attorney's application for Registered In-House Counsel in California. By carefully preparing and submitting these documents, applicants can efficiently navigate the application process, demonstrating their qualifications and readiness to serve as in-house counsel within the state.

Similar forms

The California Application Registered In-House Counsel form, designed for out-of-state attorneys seeking to serve as in-house legal counsel within California, mirrors several other legal application documents in specific ways. Notably, it is akin to the application process for pro hac vice admission, whereby attorneys licensed in another jurisdiction may request permission to participate in a specific case in a state where they are not licensed. Both applications necessitate proof of good standing in another jurisdiction and adherence to local rules, yet the in-house counsel registration allows for an ongoing capacity to work within a state, contrasting with the one-time permission characteristic of pro hac vice applications.

Similarly, the form shares commonalities with Moral Character Determination applications required for bar admission in various states. Both types of applications involve a thorough review of the applicant's background to assess moral fitness for practice. Detailed declarations and potentially the submission of a Certificate of Good Standing highlight the scrutiny faced by applicants in both contexts, ensuring that only individuals meeting the ethical standards are permitted to serve in professional legal capacities.

Additionally, this registration form resembles applications for Multi-Jurisdictional Practice (MJP) programs, enabling attorneys to practice across state lines under certain conditions. Both the California In-House Counsel application and MJP applications mandate detailed information regarding the attorney's eligibility, licensing status, and jurisdictional authority. These programs mandate strict compliance with the rules of professional conduct and continuing legal education requirements, underscoring the regulatory parallels between these distinct but related application processes.

The application also parallels the Limited License for Legal Technicians (LLLT) found in some jurisdictions, which allows non-attorneys to offer legal advice in specific areas. Although targeting different applicant groups, both entail rigorous vetting, including character assessments and educational prerequisites. This underscores a shared commitment across various legal professions to protect public interests through comprehensive scrutiny of professionals' qualifications and integrity.

Foreign Legal Consultant (FLC) applications bear resemblance as well. FLCs are attorneys licensed outside the United States who wish to offer legal advice within the U.S. on the laws of their home countries. Like the California In-House Counsel application, FLC applications require detailed professional history, proof of good standing, and are subject to specific constraints on practice scope. Both applications facilitate legal practice within a new jurisdiction while ensuring applicants abide by a defined set of regulations.

Furthermore, the document resembles bar exam applications to some degree. Both demand extensive personal and professional disclosures to ascertain eligibility and fitness for the role sought. This includes educational history, legal standing in other jurisdictions, and moral character declarations. While serving different end goals—one for initial licensure, the other for permission to practice in a specialized capacity—each process serves as a gatekeeping mechanism to ensure competence and integrity within the profession.

The form is also similar to applications for Certified Legal Specialist status available in some legal areas such as family law or immigration. These applications typically require proof of substantial involvement in the specialty area, references attesting to competence, and sometimes a written examination. Though targeting different ends—specialization within the law versus permission to serve as in-house counsel—both application types focus on documenting specific qualifications and adherence to high professional standards.

Last but not least, it bears similarity to renewal applications for attorneys, which are required periodically to maintain one's license to practice law. Both kinds of documents require current information about the applicant’s professional status, any changes in personal details, and continual adherence to ethical frameworks established by the legal community. They embody the profession's commitment to ongoing accountability and the maintenance of high standards among its members.

Dos and Don'ts

When preparing to fill out the California Application Registered In-House Counsel form, there are critical steps to adhere to for a smooth submission process. Paying attention to these dos and don'ts can significantly impact the success of your application.

Do:

  • Ensure Accuracy: Review all the information you provide for accuracy. This includes double-checking the spelling of names, dates, and ensuring that addresses and contact details are current and correct.
  • Type or Print Clearly: The form requires that all entries be legible. Typing is preferred to avoid any misunderstandings or delays related to hard-to-read handwriting.
  • Attach All Required Documents: Make a checklist of attachments A, B, C, the Application for Determination of Moral Character, and all necessary fees. Double-check that you're attaching all required documents before mailing.
  • Pay Fees with the Correct Method: Remember that personal checks are not accepted. Fees should be paid via cashier's check, travelers’ check, or money order made payable to the “State Bar of California.”

Don't:

  • Leave Sections Incomplete: Ensure every required field is filled out. Incomplete applications can cause delays and potentially result in a denial of your application.
  • Ignore the Eligibility Requirements: Before submitting your application, confirm that you meet all eligibility criteria, including being a member in good standing in at least one jurisdiction in the United States and not being suspended or disbarred elsewhere.
  • Forget to Sign and Date: Your signature is required to verify the authenticity and accuracy of the information provided. A missing signature can invalidate your entire application.
  • Overlook the Deadline for Updates: After submitting your application, you must report any changes in your information, including address or employment status, within 30 days to The State Bar of California. Failing to do so can affect your standing and eligibility.

Misconceptions

Understanding the complexities and correcting misconceptions surrounding the California Application for Registration as In-House Counsel is essential for out-of-state attorneys looking to practice within this specific legal framework. These misconceptions can lead to confusion and missteps in the application process. Here are five common misconceptions clarified:

  • The requirement of California residency for applicants: Many believe that to apply as In-House Counsel in California, one must be a resident of California. This is not accurate. The form does state the applicant currently resides in California; however, this pertains to the time of practicing under the Registered In-House Counsel Program, not at the application's filing.
  • Full scope of practice is allowed: There's a misconception that once registered, in-house counsel can represent individuals or entities beyond their employer in legal matters in California. The form explicitly states that registered in-house counsel cannot offer personal or individual legal representation beyond the qualifying institution.
  • Payment through personal checks is permitted: The application instructions make it clear that personal checks are not accepted for the payment of the application fee and the moral character determination fee. Acceptable forms of payment include cashier's checks, travelers’ checks, or money orders only.
  • Discipline from other jurisdictions does not impact the application: Another common misconception is that disciplinary actions in other jurisdictions do not affect the California application. The form requires disclosure of any prior discipline, emphasizing the importance of good standing across all jurisdictions where the applicant is admitted to practice.
  • Qualifying institutions are limited to corporations: There’s often confusion that only corporations can qualify as employers for the purpose of this registration. The form broadens this definition to include partnerships, associations, and other legal entities, provided they do not offer legal services to third parties and meet the other specified criteria.

Clearing up these misconceptions is crucial for out-of-state attorneys aiming to navigate the registration process effectively. Understanding the specifics of the California Application for Registration as In-House Counsel ensures applicants are well-informed and can adhere to the regulatory requirements laid out by the State Bar of California.

Key takeaways

When applying for the California Out-of-State Attorney Registered In-House Counsel Program, there are several critical aspects applicants must understand to ensure the process is completed accurately and effectively. Below are key takeaways regarding the application process:

  • Applicants must first register with the State Bar’s Office of Admissions before submitting the application. This initial step is crucial for eligibility verification.
  • It is imperative to type or print clearly when filling out the form to avoid any misunderstandings or processing delays due to illegible information.
  • The address provided by the registrant will become public information, accessible upon request, and will be posted on the State Bar’s website, highlighting the need for careful consideration about the details shared.
  • Two separate fees are required: a $550 application fee and a $500 moral character determination fee. Applicants should note that personal checks are not accepted, making preparation for payment via cashier's check, traveler’s check, or money order necessary.
  • A comprehensive Attorney Declaration must be completed as part of the application, confirming the applicant's good standing in at least one jurisdiction in the United States, among other declarations related to their practice and ethical commitments within California.
  • The Declaration of Qualifying Institution is also a required attachment that provides verification of the applicant's employment status and asserts the institution’s eligibility under specific criteria outlined by California Rules of Court.
  • An Admissions/Standing List is to be included, detailing the applicant's bar admission status across various jurisdictions, further demonstrating their capability and standing in the legal profession.
  • Changes in employment status, address, or eligibility to practice law must be reported to The State Bar of California within 30 days, underscoring the importance of maintaining accurate and current records with the State Bar.

By carefully adhering to these guidelines and preparing the necessary documentation thoughtfully, applicants can navigate the application process for the Out-of-State Attorney Registered In-House Counsel Program with greater ease and confidence.

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