Can the firm earn from the supplemental services it offers clients?
A research summary by Bluprint, a non-lawyer vendor, from the Rules Regulating The Florida Bar, its ethics opinions and the Florida Statutes. Not legal advice: you and your counsel are best placed to judge how it applies. It assumes you are a Florida Bar member (if you are admitted elsewhere, your home state's rules apply too).
Every citation is a link to its official source, opening at the exact page, so any line can be checked in one tap.
How sure we are: high on the core rules, which the Bar states plainly. Medium on a company run or co-owned by a firm's nonlawyer COO, which we found no Florida opinion addressing.
The firm can't keep a provider's fee. The Bar's opinions require the benefit to go to the client, passed through or credited against fees.
Opinion 70-13, Opinion 63-14, Opinion 02-8 (investment referrals, applied here by analogy)
The firm can own a separate company that sells these services and keep its profit, if each client is told in writing who owns it and that it is not a legal service, signs a consent, and the company never steers legal work to the firm.
Health insurance commissions stay with licensed agents. An agent may share them only with licensed agents or an insurance agency, so neither the firm nor a marketing company can receive them unless it is a licensed agency.
Ordered from safest to riskiest. Tap any one to see why.
No fee, so the referral-fee rules don't come into play. The firm also earns nothing.
WhyCloseOf the options here, the only one where the firm keeps what it earns. The steps are below.
WhyCloseThe Bar's ethics committee (advisory) found no outright ban on referring clients to a genuine business the lawyer owns, as long as it is more than a way around the referral-fee rules. Opinion 02-8 The conditions:
Risky even if nothing flows back to the firm, and the firm earns nothing.
WhyCloseA listing fee is still money from a vendor your clients are pointed to.
WhyCloseA company that sells nothing itself looks like a way around the referral-fee rule.
WhyCloseThe opinions require the benefit of any such fee to go to the client.
WhyCloseThe safest way to earn, start to finish.
A genuine business with its own name, run apart from the firm's legal work. Opinion 02-8, Opinion 88-15
The client pays the company directly. Its profit can go to the firm, as the Bar's sample form shows. Sample disclosure form
Who owns the company, that the firm benefits, that it is not a legal service, that the client doesn't have to use it, the terms, and written advice that they may consult independent counsel. Rule 4-1.8(a), Rule 4-5.7(d), Opinion 72-26
Where your COO fits. She could likely run or co-own this company, because the rule against partnering with a nonlawyer applies only where the activities include practicing law. That is our reading, and we found no Florida opinion on this exact setup, so it is the question for the hotline. Rule 4-5.4(c)
If the firm has any stake, the page discloses it.
Not referralsor
not [the firm], when the firm has a stake or sends its clients there. Our reading of the disclosure duty. Opinion 72-26, Opinion 73-1, Rule 4-8.4(c)
The Florida Bar's Ethics Hotline answers members in good standing about their own planned conduct. Staff views are advisory, not binding. A written staff opinion, requested in writing, takes 3 to 5 weeks. Hotline page
The question to ask
May my firm own a nonlegal company that sells relocation, insurance-referral and tax-coordination services to my immigration clients, and may my nonlawyer COO co-own or manage it?
From the Bar's official full set, dated October 22, 2026. Each link opens at the rule.