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In other circumstances, we have imposed a 60-day suspension for unintentional misrepresentations on tax returns, In re Grigsby , , 63 (Minn. 2009), and a 2-year suspension for misconduct that included misrepresentations about the attorney's actions while she was the trustee of a trust, In re Ahl , (order).

“Compliance with the law is no mitigating factor,” nor is cbmpliance with' the rules of professional conduct, Albrecht, d at 539 .

But “mere compliance with the rules of professional conduct is not a mitigating factor in attorney discipline cases.” Albrecht, d at 539 ; (concluding that cooperation with criminal and disciplinary proceedings is required by the rules and is not a factor for mitigation); (same); (same).

“Although we place great weight on the referee’s recommended discipline, we retain ultimate responsibility for determining the appropriate sanction.” ().

To determine the appropriate sanction for attorney misconduct, we consider four factors: “(1) the nature of the misconduct; (2) the cumulative weight of the disciplinary violations; (3) the harm to the public; and (4) the harm to the legal profession.”

I. In a disciplinary proceeding, the Director has the “burden of proving by clear and convincing evidence that the respondent violated the Rules of Professional Conduct.”

(“Nor is Rule 8.4(c) limited, by its terms, to intentional misrepresentations .

Four factors guide our determination of the appropriate discipline: “(1) the nature of the misconduct; (2) the cumulative weight of the disciplinary violations; (3) the harm to the public; and (4) the harm to the legal profession.”

We suspended Grigsby from the practice of law for 60 days on April 16, 2009, for conduct unrelated to his representation of J.R.

(stating that responding with “only a vague denial” and other failures to cooperate violated Rule 8.1(b), MRPC, and Rule 25, RLPR); *799 62 (Minn.2009) (stating that failure to timely respond and making misrepresentations violated rules 8.4(c) and (d), MRPC, and Rule 25, RLPR).

825 n. 3 (Minn.2010) (concluding that *304 the referee’s findings were not sufficient to establish that the attorney had committed a criminal act); , 61 n. 8 (Minn.2009) (concluding that the referee’s conclusion of law that the attorney had committed a criminal act was not supported by the record); , 336 n. 5 (Minn.2008) (concluding that the allegations of the disciplinary petition, deemed admitted due to the attorney’s fail