Structuring a Retirement Plan for Senior Lawyers
Thursday, July 10, 2008 at 10:05PMThe traditional meaning of retirement has been a single event – “withdrawal” from the workforce into leisure, relaxation, a slide into the end of life. Webster’s Dictionary defines retirement as “removal or withdrawal from an office or active service; to seek privacy or seclusion.” The word retire comes from the French word retirer meaning “to withdraw,” the same root “martyr” comes from. Perhaps, it is time to revise what we mean by retirement - indeed it may be time to re-examine the whole notion of age.
Instead of viewing retirement as an end-point in itself, lawyers need to begin thinking of retirement as a series of developmental steps taken over an extended period of time. Retirement today needs to be seen as more a journey than a destination. In order to more effectively participate in this journey, retirees will need to learn new skills and competencies well before they begin any type of retirement.
Retirement Planning as a Renewal Process
Over the past twenty years, I have worked with dozens of sole practitioners and literally hundreds of senior attorneys in developing Exit or Retirement Plans. I have found that those firms that prize the interdependence and mutual responsibility among the generations are better prepared to help their pre-retirees through this period of transition. These firms are more inclined to encourage their senior lawyers to tackle fresh assignments designed to offer variety and challenge and to stimulate new skills development. Senior lawyers in these law firms seem to approach retirement as a way of gaining renewed purpose in their lives. They want something new, something different, perhaps something novel, and certainly something interesting at deep personal levels. Law firms play an increasingly important role in creating a firm culture that will allow this transition to take place.
Richard P. Johnson, Ph.D. author of Creating a Successful Retirement: Finding Peace and Purpose indicates that a new career developmental stage is emerging, which he calls the "renewal stage." According to Johnson, this new stage of development starts for some people around the mid-fifties and lasts well into the mid-seventies. The renewal stage can be a time of great personal growth and development, or it can degenerate into just the opposite. Johnson describes this stage as, “A time for capturing a dream that may have lived in our souls for years but was unable to come out due to the obligations that pressed in on us financially. Now, in the renewal stage, these long held-down desires can begin to flow.” [1]
The renewal stage is a time when individuals begin taking a much more personal approach to living. They are free for the most part from the press of billable hours. The renewal stage is a time when even "hard-chargers" should begin re-evaluating how they live their lives. In the right environment, senior lawyers should not have to prove to anyone what they're made of. Now they should only have to answer to their own needs, their own impulses, their own passion - and their partners. That's really what renewal is all about ... pursuing your passion, your dream, your own goal—not someone else's.
Revising Strategy for the Aging Workforce
According to Jim Emerman, executive vice president of Civic Ventures, a San Francisco-based think tank that focuses on issues of redefining the role of older people, “A better way of looking at what’s happening is to see the biological, social, economic and political trends at play as the elements of a new stage of life and work—one that falls between midlife and true old age—and for which we don’t have a good name.” [2] The key to success in this new stage of life and work - renewal stage is how well a law firm can change its culture to allow this transition to take place.
The aging of the workforce is a phenomenon that law firms can no longer ignore. According to Ken Dychtwald, visionary on the implications of an aging population www.agewave.com , this phenomenon is being driven by three demographic realities—the disproportionate size of the baby boom generation, increasing longevity, and declining birthrates. [3]
The Baby Boom Generation - Nearly one third of all Americans—76 million people—were born between 1946 and 1964. [4] The first of the boomer generation are approaching their early sixties, so law firms throughout the country are facing new challenges with traditional retirement policies and procedures that define retirement in terms of removal or withdrawal. What this means is that law firms will have to figure out how they can survive this massive exodus of skilled senior lawyers.
Many of these senior lawyers will be looking to gain, “ a renewed sense of purpose ,” while too many law firms will be looking for removal or withdrawal from active service . One of the first challenges law firms face today is how to create meaningful-purposeful—roles for lawyers between midlife and true old age.
Nearly eighty percent of baby boomers say they want to work in retirement, and three million of these baby boomers are expected to live to be 100 years old. Many boomers have married late. They may have divorced, remarried, and started second and third families. Increasingly, senior lawyers find themselves caring for infants and elderly parents simultaneously, sandwiched between generations and playing multiple roles. For many of these boomers, retirement in the traditional sense may not even be an option.
Increasing Longevity - Cornell University ’s Retirement and Well-Being Study, showed 44 percent of retirees saying they would work for pay at some point after their careers. A much larger percentage of the younger cohort is likely to work post-retirement (59 percent vs. 37 percent). [5] The most popular reason for returning to work (89 percent) was to keep active, not financial need.
Around 1900, the average life expectancy at birth in the United States was forty-seven; now it is over seventy-seven [6] (figure 1-2). T he American Association of Retired People (AARP) conducts a retirement survey each year showing the top four reasons for working in retirement. Their 2003 survey results showed: staying mentally active (87 percent), staying physically active (85 percent), being productive or useful (77 percent), and doing something fun (71 percent). Other reasons given for working in retirement included: needing the money (22 percent of respondents) and needing health benefits (17 percent). It might be fair to say that the majority of today’s retirees work for pleasure, mental stimulation, and personal fulfillment as well as for money and health benefits. [7]
Declining Birth Rates - After peaking at 3.7 in the mid 1950s, the average number of children per women in the United States has declined to 2. Nearly twenty percent of baby boomers will have no children, and another twenty-five percent will have only one child. Declining birth rates guarantee a recurrent shortage of talented young workers – a problem many law firms are experiencing at this time.
In 2001, the American Productivity and Quality Center (APQC), a consortium that focused on identifying business best practices and innovative methods of transferring those methods, explored links between succession management and company leadership development process. The study pointed out that if economic growth continues at a modest 2 percent for the next decade and a half, this would result in the need for a third more senior leaders than there are today. Yet the supply of the age cohort that has traditionally entrance into the executive rankings (35 to 44 year olds) is actually declining in the U.S. and will have dropped by 15 percent between 2000 and 2015 because of the differences in the size of the baby boom generation and the much smaller Generation X. So, law firm strategists will have to look for new approaches to attract and build leadership teams.
Today, there are forty million people 65 and over (14 percent of the population). In 2030 there will be a whopping seventy million people (20 percent of the population) in this age bracket. People over the age of 85 are the fastest growing age group. People are retiring for the first time earlier and earlier. The average first retirement age has declined from sixty-five, some fifteen years ago, to around fifty-eight today. Males today can expect to live an average of 72-½ years, while females will live almost five years beyond that.
In a recent book on the talent shortage we are facing, Workforce Crisis: How to Beat the Coming Shortage of Skills and Talent, Ken Dychtwald and his coauthors Tamara J. Erickson and Robert Morison recommend that employers look to phasing as a variation on the traditional retirement model. They describe flexible retirement, as an approach that encompasses flexible roles and work styles, attracting work assignments suited to one’s experience and inclination, and reduced hours, flexible schedules, and more control over one’s time—before and after the point of official “retirement.” [8]
Once a senior lawyer begins winding down a full-time law practice, he/she may need time and possibly support as he/she moves away from the external, material, achievement definition of self, toward the more personal, intimate and, for many, the spiritual definition of self. The journey from full-time work to full-time retirement in its traditional sense may take a number of years to accomplish. Attaining a particular age does not miraculously give anyone the requisite tools, competencies, knowledge, and attitudinal shifts to ensure that retirement will proceed smoothly.
Today, we are facing a shortage, not a surplus of talented lawyers, so law firms must begin to phase out “retirement” as we know it. As a replacement, law firms need to explore how a staged reduction in work hours and responsibilities ahead of full retirement might work. Could it be that the same senior lawyers that many law firms are now looking to sunset may become the untapped resources firms will need to lead the talent pool of the future?
Flexible Retirement as part of a Renewal Process
In my experiences with senior lawyers over the years, senior lawyers or pre-retirees are clearly not looking to fade away. They want to find fulfilling activities. They want enriching endeavors. Certainly they want to leisure... at times, and they naturally want to have fun. But, contrary to the popular media view of retirement, the most important thing lawyers anticipating retirement are looking for is their own fulfillment...their own sense of purpose and meaning. The idea of a more flexible retirement option, would allow not only partial retirement, so that senior lawyers can enjoy other pursuits, but also active retirement, wherein seniors can remain productively and socially engaged in the workplace. Going to a more flexible retirement option will demonstrate a fundamental shift in the way lawyers of all ages live their lives.
Before law firms can begin looking at retirement as a journey or a process that may begin for some individuals as early as the mid-fifties, law firms will have to re-examine how they have been determining value throughout the whole organization. Many firms determine partner value based almost exclusively on billable hours. Every partner may have the same goal of billing 1,800 billable hours.
As more partners begin reaching senior status, it should be anticipated that more of your senior people will be unable to keep up with targeted hours. When lawyers define themselves by hourly rates and billable hours, one hour is not distinguishable from that of a competitor's, so clients will begin thinking of you--and the services you offer--as commodities. If you believe that all you can offer your clients is time, and you behave as if logging hours on a timesheet is more important than actually servicing the needs of clients by delivering results, you are ready to explore new ways to create client value. Unless law firms are able to look at the creation of value for their senior lawyers in new ways, law firms will never be able to change their cultures to allow this transition to take place.
David H. Maister, widely considered to be one of the world's leading authorities on professional service firm management says, “There exists in many large firms a Lost Generation of professionals who become partners by keeping their heads down, putting in vast numbers of billable hours on work generated by others, abdicating control over their own work lives to “the machine,” and never being required to demonstrate individual initiative.” [9] These are not the senior lawyers who will be interested in staying connected with the business they built.
In my experiences with transition planning, many senior lawyers may need outside assistance to help them through this transition process. With the proper planning and support, flexible retirement should hold up as a new prospect of growth for your senior lawyers, their loved ones, and the entire law firm community.
Renewal Strategy to Gain Competitive Advantage
William Bridges, author of “Managing Transition: Making the Most of Change” defines Transition as the inner process through which people come to terms with a change. The process takes place over a period of time as they let go of the way things used to be and reorient themselves to the way that things are now. Transition management is based on the idea that the best way to get people through transition is to affirm their experience and to help them to deal with it. In a law firm setting, managing transition means helping people to make that difficult process less painful and disruptive. Many law firms have been following the mistaken idea that the best way to get people through a transition is to deny that they are even in a transition.
Getting through transition is not easy. Each individual will need to start where the transition itself starts: with letting go of the inner connections to the way things were. As we age, we will be faced with how we might cut back in full-time employment. What are some of the things senior lawyers might have to let go of? Income will certainly be affected; definitely there may be a loss of intellectual challenge; possible a loss of a group of colleagues and friends; a regular place to go every morning; the familiar way you have structured your time over many years. You also will be confronted with the possible lose of professional identity. These are some of the things that leaving the full-time practice of law will force the senior lawyer to think about losing.
In order for law firms to help senior lawyers through this transition/renewal stage of life, they need an adequate change management plan in place. They should determine where senior lawyers are in the transition process, and they will need to develop strategies for helping people let go of the old way of doing things. Bridges talks of the need for guiding people through the neutral zone, and utilizing that in-between state creatively. Only after working through such a process will the firm be ready to fully appreciate the true value senior lawyers can bring to the aging marketplace. People will only then be able to fully embrace the new ways of doing and being.
The American Society of Aging (ASA) follows emerging trends in healthcare, mental health, long-term care, lifelong learning, commerce, spirituality, mental health, long-term care and other domains of increasing importance to our aging population. Law firms should begin looking very closely at the trends. [10]
Wellness - Wellness covers a broad range of topics from self-responsibility to global healing. The antidote to stress is what is generally referred to as "happiness" or "well-being." A large body of research indicates that happiness prolongs life and improves health. [11] By happiness, I am talking about feeling that your life has purpose and meaning; doing work that is challenging and engaging and allows you to develop your strengths and potential; enjoying supportive and intimate connections with other people; accepting yourself – your vulnerabilities and mistakes as well as your strengths and successes; and living your life intentionally, so that rather than operating on auto pilot, you are conscious of the moments of your life and grateful for the small blessings one misses without such mindful awareness. [12]
Programs in this area might include: helping individuals eat right, exercise better, and be a better health care consumer. If individuals need more specific information about mental health problems, alcohol and drug abuse or other forms of addition one can only hope that law firms are working with bar associations to get help to lawyers in need. To improve the health of your senior lawyers, Wellness programs may be a logical place to start. Balancing Life
Cognitive Fitness –Research indicates that there is strong evidence to indicate that exercise may forestall some kinds of mental decline. Arthur Kramer, one of the preeminent exercise and brain-health researchers in humans at the University of Illinois at Urbana-Champaign has conducted a number of studies that have proven two critical findings: Fit people have sharper brains, and people, who are out of shape, but then get into shape, sharpen up their brains. [13] This has some very interesting implications for has always prided themselves on the number of hours worked each day.
Increasingly, law firms will find that Cognitive Fitness programs for all lawyers will be in their own best interest. Firms that offer interesting and unusual training programs in all areas of thinking like Creative Thinking, Critical Thinking, Problem Solving, Learning How to Learn and Learning Styles will give senior lawyers greater opportunities to remain productively and socially engaged in the workplace .
Retaining Top Talent – In October 2006, business executives and managers were surveyed by AARP to find out how prepared companies are for the fundamental shifts that will occur in the workplace as the baby boomers approach traditional retirement age. [14] Few report that their companies have taken action to mitigate the potential impact on their competitiveness.
· 79 percent agree that the knowledge and experience that older employees take with them when they retire or leave can hurt a business financially.
· 74 percent similarly agree that it has become more difficult to find and retain talented and qualified employees over the last five years.
Retaining senior talent is clearly one of the areas where progressive law firms can gain significant competitive advantage. The knowledge and experiences that senior lawyers take with them when they leave the firm may not be able to be replaced very quickly.
Conscious Aging Movement – The conscious aging movement employs a proactive strategy that intentionally creates supportive neighborhoods and networks. Aging in community promotes well-being and quality of life for elders at home and as an integral part of the community. It makes perfect sense that law firms can do a great deal more to help lawyers stay connected -- a sense of trust and mutual interconnectedness, enhanced over time through positive interactions and collaboration in shared interests. According to the nation's two largest professional associations in aging -- The American Society on Aging (ASA) and the National Council on Aging (NCOA), Aging in Community is philosophically rooted in the “conscious aging” movement that views “elderhood” as a distinct phase of the human life cycle, with its own gifts and challenges.
According to Robert C. Atchley, chair of the Department of Gerontology at Naropa University, Boulder, Colorado, the vision laid out by the early framers of the "aging with consciousness" movement involves developing and nurturing a contemplative life and engaging in service rooted in the higher levels of consciousness that a contemplative life makes available. [15] Growing old with awareness or being spiritually awake as we age, certainly seems consistent with senior lawyers seeking to pursue their passions, their dreams, and their personal goals. As more and more middle-aged and older lawyers become interested in making an inner journey or spiritual discovery as part of their renewal/retirement process, interest in "conscious aging" will grow.
Increasing Diversity – Dramatic changes in workforce composition, together with changing immigration and education patterns, produce a workforce that will be much more diverse—not only in age gender and ethnicity, but also in background, lifestyle, needs, preferences, and values. [16] Ken Dychtwald and his colleagues at Age Wave conducted a year-long study of an aging and diversifying workforce where they concluded that, e mployers should be planning to double the proportion of workers 55 and older. The average age of employees will continue to rise and the workforce will become more multigenerational during the next 5-10 years. [17]
Demographic and economic projections suggest that the shortage of workers will start soon and grow significantly, but the Employment Policy Foundation (EPF) estimates that 80 percent of the impending labor shortage will involve skills, not numbers of workers potentially available. [18] There are simply not going to be enough young lawyers entering the marketplace to counteract the labor, skills and talent drain of the impending wave of boomer retirements.
Increasing Business Interests in Marketing to Baby Boomers – Most marketing is still youth oriented even though today’s mature adults, (those over 50) control two thirds of the accumulated wealth in the United States. [19] Boomers are already the most financially powerful generation of mature consumers ever, so law firms should not only act immediately to avoid the potentially debilitating “brain drain” of skills and experience, but firm’s should also reassess their allocation of resources to make sure sufficient funds are devoted to serving aging clients and their changing needs.
Change in Law Firm Culture - Full Engagement Model
Because lawyers have so much discretion and autonomy in a law firm setting, firm culture is the dominant force in determining how lawyers in any firm actually behave towards one another and towards their clients, so one of the first challenges that law firms will face in the years ahead will be finding ways of changing the firm culture to ensure an adequate supply of qualified lawyers.
Many law firms remain mired in the notion that the only way to create wealth is by leveraging people and hours; that the two main drivers of profitability are leverage (number of associates or paralegals per partner) and the hourly rate utilization achieved by each team member. The thinking has been that if a firm wants to add to its revenue base, partners have two choices: work its people more hours or hire more people.
Confronted with new forms of competitive and market challenges, the practice of law is long past due for a new way of looking at profitability in law firms. It is also long past due for a new way of looking at its lawyers – including senior lawyers. It’s time for a new business model that will attract individuals who are fully engaged, physically energized, emotionally connected, mentally focused, and spiritually aligned with a purpose beyond immediate self-interests. This Full Engagement Model begins with an eagerness to go to work in the morning, equal happiness to return home in the evening, and a capability to simply set clear boundaries between the two. Full engagement implies a fundamental shift in the way lawyers - young and old - live their lives.
In discussing this new business model, let’s start by agreeing that clients are not interested in buying time. They are interested in buying: results, expectations, good feelings, hope, dreams, a preferred vision of the future, and solutions to problems. Today, a lawyer’s ability to create wealth ultimately depends on the firm’s capacity to create, disseminate, innovate, and leverage intellectual capital, so firms must begin pricing their intellectual capital based upon the value to the client, not the internal labor cost of its human capital; or the profit desires of its owners, and certainly not the labor hours involved in creating it. [20] Keep in mind that intellectual capital in most law firms resides with the most experienced people – your senior lawyers.
Two aspects of this new law firm culture that young people are now demanding include: a strong performance orientation and an open, trusting environment. It logically follows that, law firms whose culture supports both a performance orientation (which includes inspiring mission, stretch goals, accountability for results, and tight performance systems) and an open, trusting environment will have a much greater chance of attracting and retaining talented people. Two aspects of this new law firm culture that senior lawyers are now demanding include: a strong performance orientation and an open, trusting environment.
With the emergence of this new Full Engagement Model , the success factors of the past will increasingly becomes less relevant. Billable hours will become less meaningful to clients, and the criteria for success in the future have yet to be established. This new law firm culture will create the framework for setting new performance expectations and the ways in which people relate to one another. I suspect that “quantifying senior lawyers continuing involvement” will become a much sought after standard.
Coaching
For years, David H. Maister, widely considered one of the world's leading authorities on the management of professional service firms, has been promoting skilled managers and team leaders whose job it is to manage the team and coach the individual players. In David H. Maister ‘s book Practice What You Preach, he shows (statistically) that success in professional business actually returns greater profits to the firms that provide coaching to individuals than firms that provide no coaching or mentoring.
The phenomenon sometimes called phased retirement is becoming increasingly more common among all many white-collar professionals. Increasingly, professional service firms are turning to retirement coaches or mentors to help senior partners set retirement goals and exit strategies. As a rule, Retirement Plans include both long-term goals (e.g., to continue working three-days a week for two more years) and the more immediate performance goals that move lawyers toward those long-term goals (e.g., to transition ten of my clients to younger partners in the next thirty-days).
An ever-increasing number of professional coaches are being brought in to work with sole practitioners and senior partners in firms of all sizes. Research shows that individuals who are able to set goals for themselves that are Specific, Measurable, Achievable, Realistic, and Time-limited (SMART) are much more successful in achieving what they wished to accomplish. When the goals are for the individual’s own benefit, motivation increases, and success of the relationship is assured.
Persons approaching their first retirement transition need exactly the same process of self-analysis and sound consultation that they would receive from a competent career consultant if they were going through a job change. Time to work on such a plan is very hard to do with other responsibilities in a busy law practice. As job changers need to generate their career options in a clear and understandable way, so too, pre-retirees need the same "options generation" process but with slightly different content, slightly different goals, and an entirely different purpose. That's exactly what persons approaching retirement at any age need ... they need OPTIONS.
Throughout the country, coaching has achieved wide spread recognition as being of value, relevance and importance in business, and we are now beginning to see increasing numbers of independent coaches working in the legal marketplace. Innovative law firms are now beginning to offer senior partners assistance in finalizing retirement plans through the use of outside coaches, who have specialized in retirement planning.
The coaching engagement is generally provided through a series of confidential telephone consultations made over a period of three to six-months. Individual attorneys can invest in retirement coaching on their own; however, there are a number of benefits law firm can get from extending coaching as a pre-retirement benefit. The number one benefit to law firms is from helping the senior people who built the firm determine how they might want to continue to be involved with the firm in the future.
Stephen P. Gallagher , president of Leadershipcoach.us, an executive coaching firm that works with attorneys, practice group leaders, and “high potential” individuals to develop exit strategies and Retirement Plans. Gallagher also works with management teams to help firms adapt to change, build a sustainable, more profitable law practice, that will support individuals in working less hours and thus achieving balance in your professional and personal life.
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Reference:
Johnson, Richard P. Creating a Successful Retirement: Finding Peace and Purpose (Liguori, MO: Liguori Publication, 1999).
Leider, Richard J. The Power of Purpose: Creating Meaning in Your Life and Work (San Francisco: Berrett-Koehler Publishing, Inc., 1997).
Sedlar, Jeri and Rick Miner Don’t Retire, REWIRE: 5 Steps to Fulfilling Work That Fuels Your Passion, Suits Your Personality, Or Fills Your Pocket (Indiana: Alpha Books, 2003), p. xiii
[1] Richard P. Johnson, Ph.D. Creating a Successful Retirement: Finding Peace and Purpose (Liguori, Missouri: Liguori Lifespan Publishing, 1999), 42.
[2] Jim Emermen, “On Life’s New Stage—and Its Challenge to the Field of Aging.” Aging Today: The Bimonthly Newspaper of the American Society of Aging, Sept– Oct 2006, 3.
[3] Ken Dychtwald, Tamara J. Erickson and Robert Morison, Workforce Crisis: How to Beat the Coming Shortage of Skills and Talent ( Boston : Harvard Business School Press, 2006), p 3.
[4] U.S Census Bureau, Population Division, Statistical Brief. Sixty-Five Plus In The United States, May 1995.
[5] The Cornell Retirement and Well-Being Study, Phyllis Moen, PhD Principal Investigator. Journals of Gerontology Series B: Psychological Sciences and Social Sciences Online, 2000.
[6] Health, United States, 2005, www.edc.gov/nchs/hus.htm .
[7] AARP, “Staying Ahead of the Curve 2003: The AARP Working in Retirement Study,” September 2003.
[8] Ken Dychtwald, Tamara J. Erickson and Robert Morison, Workforce Crisis: How to Beat the Coming Shortage of Skills and Talent (Boston: Harvard Business School Press, 2006), p. 52.
[9] David H. Maister, (1997). True professionalism: The courage to care about your people, your clients, and your career (New York: Free Press) p. 27.
[10] Jim Emermen, “On Life’s New Stage—and Its Challenge to the Field of Aging.” Aging Today: The Bimonthly Newspaper of the American Society of Aging, Sept– Oct 2006, 3.
[11] See David G. Myers, Pursuit of Happiness: Who Is Happy – And Why (New York: Morrow Books, 1992).
[12] See Carol D. Ryff & Corey Lee M. Keyes, The Structure of Psychological Well-Being Revisited, 69 Journal of Personality Social Psychology (1995) 719.
[13] William Speed Weed, 7 Ways to Make your Brain Better, Faster, and Smarter, Reader’s Digest August 2006.
[14] Business Executives’ Attitudes Toward the Aging Workforce: Aware But Not Prepared ? Research Report - Business Week Research Services, October 2006.
[15] Robert C. Atchley, Conscious Aging: Nurturing a New Vision of Longevity WellnessGoods.com website http://www.wellnessgoods.com/consciousagingnurturing.asp . Nov. 2006
[16] Changing Workforce Demographics and Management Challenges: Part I
http://www.mcgraw-hill.co.uk/tpr/chapters/1591395216.pdf
[17] Demography Is De$tiny, a Concourse Group and Age Wave study sponsored by thirty major organizations. It led to a companion project, The New Employee/Employer Equation, in which Harris International conducted a poll of over seventy-seven hundred employees nationwide.
[18] Testimony of Edward E. Potter, president, Employment Policy Foundation, before the Special Committee on Aging of the U.S. Senate, September 20, 2004, 5.
[19] Ken Dychtwald, Tamara J. Erickson and Robert Morison, Workforce Crisis: How to Beat the Coming Shortage of Skills and Talent (Boston: Harvard Business School Press, 2006), p. 13.
[20] Dunn, P. & Baker, R. The firm of the future: A guide for accountants, lawyers, and other professional services (Hoboken, NJ: John Wiley & Sons, Inc. 2003), p.28.


