through litigation (or similar legal practices). (8) In recent years, the Consumer Financial Protection Bureau has also aggressively sought to regulate attorneys’ collection activities, including their litigation activities, despite the broad practice of law exclusion in section 1027(e) of the Consumer Financial Protection Act. The Bureau’s aggressive actions could also lead to other Federal agencies adopting rules or practices regulating attorneys’ litigation activities in other types of court cases. (9) These developments have undermined State and Federal courts’ primary and inherent authority to regulate and oversee attorneys engaged in the practice of law by creating multiple conflicting sets of rules and standards for attorneys, resulting in unfair lawsuits against attorneys pursuing valid legal claims for clients in court, increased attorney malpractice insurance rates, difficulty in obtaining legal representation, and reduced access to justice. (10) On January 26, 2011, the Conference of Chief Justices adopted Resolution 1 ( In Support of Preserving Traditional State Court Regulation of Lawyers and Opposing Expanded Federal Agency Regulation of Lawyers and the Practice of Law ), affirming that primary regulation and oversight of attorneys and the legal profession should continue to be vested in the State courts, not Federal agencies or Congress, and that the courts are in the best position to fulfill that important function. The Resolution also expressed support for Congress and Federal agencies’ decisions to include broad practice of law exclusions in certain Federal statutes and agency rules, and opposition to Federal legislation or rules intended to establish or expand the Federal regulatory jurisdiction of attorneys engaged in the practice of law. (11) While the activities constituting the practice of law are determined by the State in which an attorney is licensed or admitted to practice, litigation activities in connection with a legal action in State or Federal court are considered to be part of