---
title: "List issues for a client letter on federal lease title or a transfer"
url: "https://ailawframework.com/practice/energy-resources-and-mining/draft-a-client-advice-letter-on-title-approvals-or-project-status/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A13-T1-R13-US"
practice_area: "Energy, Resources & Mining"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List issues for a client letter on federal lease title or a transfer

> List each title, approval, and transfer issue the documents support, with the page. Do not write the letter that is sent to the client and do not state that the Bureau of Land Management has approved a transfer.

Canonical page: https://ailawframework.com/practice/energy-resources-and-mining/draft-a-client-advice-letter-on-title-approvals-or-project-status/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Energy, Resources & Mining](https://ailawframework.com/practice/energy-resources-and-mining.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List each title, approval, and transfer issue the documents support, with the page. Do not write the letter that is sent to the client and do not state that the Bureau of Land Management has approved a transfer. |
| What the lawyer must review | 43 C.F.R. § 3106.10 provides that the rights of a transferee of a federal oil and gas lease are not recognized until the authorized officer approves the transfer, and that a request for approval must be filed within 90 days from the date the transferor signs and dates it. Section 3106.71 provides that approval is for administrative purposes only and does not warrant or certify that either party holds legal or equitable title. Section 3106.72 provides that the lessee or sublessee remains responsible for lease obligations until approval, and for obligations that accrued before approval. ABA Formal Opinion 512 (29 July 2024) leaves the lawyer responsible for a draft produced with a generative tool. The lawyer writes any letter that is sent. The issue list is not that letter. |
| Written for | United States |
| Applies to | [Draft a client advice letter on title, approvals or project status](https://ailawframework.com/practice/energy-resources-and-mining/draft-a-client-advice-letter-on-title-approvals-or-project-status.md) |

## Checking plan

- What the AI does: List each title, approval, and transfer issue the documents support, with the page. Do not write the letter that is sent to the client and do not state that the Bureau of Land Management has approved a transfer.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The list does not say that title is good. Section 3106.71 says BLM approval does not certify title.
- A private joint-operating agreement can add a consent the regulations do not. The lawyer reads that clause before the letter is sent.

## Sources

- [43 C.F.R. Part 3100, Subpart 3106 (transfers by assignment or sublease)](https://www.ecfr.gov/current/title-43/subtitle-B/chapter-II/subchapter-C/part-3100/subpart-3106) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Letter of advice: duty to notify a pollution incident and the client's exposure (NSW)](https://ailawframework.com/precedents/energy-resources-and-mining/pollution-incident-duty-to-notify-advice-letter.md) | Letter | Red | Privileged advice letter to a resources or energy client after a spill or discharge: whether Part 5.7 of the POEO Act applies, who must notify and when, what information must follow, penalty and… |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*