In recent years, the California State Bar Association has stepped up its enforcement of California's Minimum Continuing Legal Education (MCLE) requirement for lawyers by auditing the compliance of more of its lawyer-members. In 2013, the Bar has announced plans to audit 10% of Compliance Group 1 (comprised of attorneys with names ending in the letters A-G). Attorneys in MCLE Compliance Group 1 are due to report their completed MCLE courses on February 1, 2013. We have seen it estimated that the planned 10% audit target for MCLE Compliance Group 1 could include as many as 7,000 lawyers.

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In 2012, the California State Bar Association's random selection of 635 attorneys in MCLE Compliance Group 3 (last names ending in letters N-Z) resulted in 27 attorneys being referred to the Bars' Office of Chief Trial Counsel, with formal charges being filed against three of them. Later that year, the California Bar expanded its audit to include 2600 attorneys in Compliance Group 2 (last names ending in letters H-M) - roughly 5% of that group. Results of that audit have not yet been made available.