Today’s mail was not dramatic.
It was procedural.
And that’s exactly why it matters.

I filed three separate Unlicensed Practice of Law (UPL) complaints with The Florida Bar. This week, I received written confirmation that each complaint has been accepted and is under investigation by the Bar’s UPL Department.

No conclusions.
No outcomes.
Just jurisdiction, intake, and process.

That alone tells you something.

Primary Source Documents

The Florida Bar’s written acknowledgments confirming receipt and investigation of all three UPL complaints are available here:

→ View the Florida Bar Letters (Redacted PDF)

What the Letter Says — and What It Doesn’t

The Florida Bar confirmed receipt of each complaint and stated, plainly, that it is conducting an investigation and will keep me advised of the status.

That’s it.

This is not discipline.
This is not enforcement.
This is not a finding of wrongdoing.

It is the Bar doing its job: determining whether non-lawyers crossed into conduct that Florida law reserves to licensed attorneys.

Why UPL Matters (Especially in the ESA Space)

Unlicensed Practice of Law is not a technicality. It exists to protect the public from legal advice delivered without licensure, accountability, or ethical oversight.

In the ESA ecosystem, the line gets crossed quietly and often.

When non-lawyers:

• Draft legal conclusions about housing rights
• Tell consumers what landlords “must” or “cannot” do
• Sell documents framed as legally sufficient determinations
• Interpret federal HUD guidance as binding state-level mandates

they may not just be mistaken — they may be practicing law without a license.

That question is now formally in front of the Bar.

What Happens Next (Procedurally)

Here’s the part people often misunderstand.

Most UPL complaints do not advance beyond initial intake. They are screened out quickly if the allegations are speculative, conclusory, or outside the Bar’s jurisdiction. Only a small fraction proceed to a formal investigation, which requires a threshold showing that the alleged conduct, if true, could constitute the practice of law by a non-lawyer.

These complaints cleared that bar.

That does not mean a violation occurred.
It means the issues raised are sufficiently concrete, jurisdictionally grounded, and non-frivolous to warrant investigation by Bar counsel.

That distinction matters.

Why This Isn’t About “Winning”

This is not a victory lap.
It’s not a press stunt.
And it’s not about punishment.

It’s about forcing clarity into a space that thrives on ambiguity.

The ESA market has become saturated with legal-sounding claims, authoritative declarations, and documents presented as determinative — often by people who are not licensed to make them.

UPL enforcement cuts through all of that. It asks a narrow, unemotional question:

Were you doing something the law reserves for licensed attorneys?

That question is now being asked — formally.

Bottom Line

The Florida Bar does not open investigations casually.
It also does not prejudge outcomes.

This is the system engaging at the correct layer — not social media, not outrage, not opinion — process.

I’ll update when there is something concrete to update.

In the meantime, these issues — UPL exposure, ESA documentation misuse, and the boundary between guidance and legal advice — are addressed in depth in my ongoing CLE and professional training work. Details will follow as dates are finalized.

Quiet.
Documented.
On the record.

FAQS

Q: Does this mean the Florida Bar found someone guilty of UPL?
A: No. An investigation means the Bar is examining whether alleged conduct could constitute unlicensed practice of law. No conclusions have been reached.

Q: Is an investigation the same as discipline?
A: No. Discipline occurs only after findings and formal proceedings. An investigation is a preliminary, fact-gathering stage.

Q: Why is UPL an issue in the ESA space?
A: Because non-lawyers sometimes issue documents or advice framed as legally determinative, interpret statutes, or present HUD guidance as binding law.

Q: Are HUD guidelines legally binding?
A: HUD guidance is persuasive but not law. Treating it as mandatory legal authority can raise UPL concerns when done by non-lawyers.

Q: What happens next?
A: The Bar reviews facts, evaluates jurisdiction, and determines whether further action is warranted. Many investigations close without enforcement.