Lawyers also report that legal aid payments do not cover the basic cost of conducting independent investigations or consultations with experts. Many lawyers describe having to subsidise the cost of cases from their own resources. Although lawyers report that the subsidy for representing a death penalty case in the first instance trial has increased, remuneration for subsequent stages – appeal, second instance trial, Supreme People’s Court review - was wholly inadequate. Private efforts to raise funds to support complex legal cases from within the increasingly affluent Chinese legal community were abandoned following the introduction of the Charity Law and restrictions on online fundraising by unregistered groups. 44