I had a general retainer to provide legal services to a client before the rules were enacted. I have just been asked to provide legal advice on a new matter. I have not opened a new file. Do I have to identify this client?
Yes. The question is not whether you have opened a new file since the rules were enacted, but whether you are providing legal services on a new matter. Since the matter on which you are providing legal advice arose after implementation of the rules, you are required to identify your client.