Working Group on Model Rules of Representative Conduct

Project Contacts

Staff Counsel

In Recommendation 2021-9Regulation of Representatives in Agency Adjudicative Proceedings, the Administrative Conference of the United States recommended that the ACUS Office of the Chairman “consider promulgating model rules of conduct” consistent with the Recommendation and, in doing so, “seek the input of a diverse array of agency officials and members of the public, including representatives who appear before agencies, and the American Bar Association.”

The Office of the Chairman has convened a Working Group of public- and private-sector representatives to develop model rules of representative conduct that, as contemplated by Recommendation 2021-9, “account for variation in agency practice and afford agencies the flexibility to determine which rules apply to their adjudicative proceedings.” The resulting model rules are intended to help federal agencies amend or develop their rules governing representatives in adjudicative proceedings consistent with the best practices identified in Recommendation 2021-9.

Working Group Members and Associated Individuals

Reporter: Louis J. Virelli III, Professor of Law, Stetson University College of Law

Staff Counsel: Alexandra Sybo, Attorney Advisor, Administrative Conference of the U.S.


  • Erin M. Wirth (Chair), Chief Administrative Law Judge, Federal Maritime Commission

  • George M. Cohen, Associate Dean for Curricular Programs and Brokaw Professor of Corporate Law, University of Virginia School of Law

  • Stefanie K. Davis, Senior Associate General Counsel and Ethics Officer, Office of Legal Affairs, Legal Services Corporation 

  • William Funk, Lewis & Clark Distinguished Professor of Law Emeritus, Lewis & Clark Law School

  • Jeremy S. Graboyes, Director of Public and Interagency Programs, Administrative Conference of the U.S.

  • Nancy J. Griswold, Deputy Director, Office of Workers’ Compensation Programs, U.S. Department of Labor

  • Allyson N. Ho, Partner, Gibson, Dunn & Crutcher LLP

  • Wendy J. Muchman, Harry B. Reese Professor of Practice, Northwestern University Pritzker School of Law  

  • Nina E. Olson, Executive Director, Center for Taxpayer Rights

  • David Pang, Administrative Law Judge, Social Security Administration

  • Lauren Alder Reid, Assistant Director, Office of Policy, Executive Office for Immigration Review, U.S. Department of Justice

  • Lea Robbins, Senior Staff Attorney, National Organization of Social Security Claimants’ Representatives

  • Roxanne L. Rothschild, Executive Secretary, National Labor Relations Board

  • James J. Sandman, Distinguished Lecturer and Senior Consultant to the Future of the Profession Initiative, University of Pennsylvania Carey Law School; President Emeritus, Legal Services Corporation

  • Anthony C. Scire, Chief Counsel and Veterans Law Judge, Board of Veterans’ Appeals, U.S. Department of Veterans Affairs

  • William A. Stock, Partner, Klasko Immigration Law Partners, LLP