Even for in-house counsel who must satisfy mandatory CLE requirements, budget constraints often limit the choices those lawyers have to satisfy the requirements. One law department holds the line by limiting CLE to on-line providers.
Compounding the lack of funds, law department lawyers may find themselves too specialized in comparison to the level of instruction at typical CLE survey courses.
Geography can pose other problems. There simply are not enough local CLE opportunities that offer more in an area of law than in-house counsel already know. Law firms might fill some of the gap, but in the end, in-house counsel might just go through the motions.