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Last Post 01 Dec 2025 06:05 PM by �Marquita Brazil
7-209 Alternative Business Structures
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Marquita Brazil
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Posts:2 New Member

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31 Oct 2025 03:43 PM
    Marquita Brazil, ABS Program Manager
    Committee on Alternative Business Structures
    Arizona Administrative Office of the Courts
    1501 W Washington St., Ste. 104
    Phoenix, Arizona 85007
    [email protected]

    Comment deadline: November 30, 2025

    Specifically, the proposed changes are as follows:

    (1) update Authorized Person to economic interest of 25% or more from 10% or more;
    (2) add “inactive” as it relates to the definition and process in ACJA 7-201;
    (3) add grounds for recommendation for denial of initial license of a disbarred or currently suspended compliance lawyer;
    (4) clarify the process for an ABS to go “inactive”;
    (5) clarify Compliance Lawyer responsibilities, including limiting the number of ABSs a CL can serve;
    (6) clarify whether a firm may continue to offer services without a Compliance Lawyer or Arizona lawyers; and
    (7) add semi-annual audit at 6-month intervals starting from the date of licensure to align with the Court’s AO language.
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    SB Seymann
    New Member
    Posts:1 New Member

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    18 Nov 2025 02:09 PM
    I noticed the addition of G(2)(c), which requires each ABS to "Maintain an active Arizona licensed Lawyer in good standing at all times." I think it would be helpful to clarify whether an approved Compliance Lawyer can meet this requirement - i.e., whether the "active licensed lawyer in good standing" and the Compliance Lawyer can be the same person. Thank you for your consideration.
    Marquita Brazil
    New Member
    Posts:2 New Member

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    01 Dec 2025 06:05 PM
    Thank you for your comment. Please note, that G(2)(c) outlines what ach ABS "must do"-maintain an active Arizona licensed Lawyer in good standing at all times. G(3)(a) speaks to what qualifications the compliance lawyer "must" have, which G(3)(a)(1), points to Supreme Court Rule 31.1(a)(1) . Supreme Court Rule 31.1(a)(1) outlines the qualifications required to practice law in Arizona. In effect, both provisions establish the same requirement, and the Compliance lawyer is the same person.
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