Blog · June 10, 2026 · 16-minute read

Bank regulatory compliance attorney time tracking: OCC Matters Requiring Attention remediation advisory call cycle, FDIC consent order compliance monitoring billing gap, and Federal Reserve SR letter implementation advisory fee petition mechanics

Q: How does the Equal Access to Justice Act apply to OCC and FDIC enforcement defense proceedings?

The Equal Access to Justice Act operates through two parallel provisions depending on the proceeding type. 5 U.S.C. § 504 applies to 'adversary adjudications' before federal agencies — formal proceedings under 5 U.S.C. § 554 where an agency seeks to impose an adverse finding on a party. OCC and FDIC cease-and-desist proceedings under 12 U.S.C. § 1818, formal removal and prohibition proceedings, and civil money penalty proceedings before administrative law judges qualify as adversary adjudications under 5 U.S.C. § 551(7) because they are formal hearings required by statute with the right to present evidence and argument. 28 U.S.C. § 2412(d) applies to civil actions in federal court against the United States — including judicial review actions where a bank challenges an OCC or FDIC order in a district court proceeding. In both contexts, the fee-shifting standard is identical: the prevailing party — the bank — is entitled to attorney fees and expenses unless the agency's position was 'substantially justified.' Pierce v. Underwood, 487 U.S. 552 (1988), defines 'substantially justified' as having 'a reasonable basis in both law and fact' — not requiring that the agency win, but requiring more than mere reasonableness of the agency's factual investigation. The EAJA petition must be filed within 30 days of final judgment in civil actions (28 U.S.C. § 2412(d)(1)(B)) or within 30 days of final disposition in agency adversary adjudications (5 U.S.C. § 504(a)(2)). Scarborough v. Principi, 541 U.S. 401 (2004), confirmed that EAJA applications are subject to amendment to add the substantial-justification allegation even after the 30-day deadline in limited circumstances. The EAJA lodestar framework follows Hensley v. Eckerhart, 461 U.S. 424 (1983): the number of hours reasonably expended multiplied by the reasonable hourly rate, subject to a degree-of-success proportionality adjustment when the bank prevailed on fewer than all enforcement claims.

Bank regulatory compliance practice concentrates three categories of external-schedule advisory work — OCC examination-cycle MRA remediation, FDIC Section 8(b) consent order compliance monitoring, and Federal Reserve SR letter implementation — where the billing gap structure is identical across all three: each failure mode is driven by a federal regulator who issues phase-transition documents on its own examination and enforcement calendar, generating advisory calls that arrive entirely on the regulator's schedule, not the attorney's billing system. When any of these matters escalates to a formal enforcement proceeding and the bank prevails, the Equal Access to Justice Act applies — but only contemporaneous records survive the Welch temporal clustering inference.

TL;DR

Failure mode 1 — OCC MRA remediation advisory call cycle: 12.8 untracked hours = $5,760–$9,600/year (5 MRA clients × 7 remediation advisory calls × 40 min × 55% untracked at $450–$750/hr).
Failure mode 2 — FDIC Section 8(b) consent order compliance monitoring call cycle: 11.0 untracked hours = $4,950–$8,250/year (3 consent order clients × 8 compliance monitoring calls × 50 min × 55% untracked).
Failure mode 3 — Federal Reserve SR letter implementation advisory call cycle: 9.2 untracked hours = $4,140–$6,900/year (4 SR letter clients × 6 implementation advisory calls × 42 min × 55% untracked).

Total: 33.0 untracked hours = $14,850–$24,750/year. All three billing failure modes are driven by external regulatory calendars — the OCC examination cycle, the FDIC consent order quarterly attestation deadline, the Federal Reserve SR letter remediation milestone timeline — not by the attorney's own workflow. When a bank prevails in a formal enforcement proceeding, EAJA 5 U.S.C. § 504 fee-shifting requires contemporaneous records for every call in the defense record.

The OCC MRA remediation advisory call cycle: 12.8 untracked hours = $5,760–$9,600/year

The OCC's Matters Requiring Attention system is the core supervisory tool through which the agency drives safety and soundness improvements at national banks and federal savings associations. The OCC Comptroller's Handbook "Bank Supervision Process" defines MRAs as findings in the examination report where the examiner has identified practices, deficiencies, or risk management weaknesses that require board and management attention and corrective action. Unlike informal examiner comments — which may appear in examination reports as observations without mandatory response requirements — MRAs carry a formal remediation obligation: the bank must submit a written board resolution committing to corrective action within 30 days of the examination report, followed by a corrective action plan with specific milestones and timeframes. The OCC schedules a follow-up examination or interim progress review within 90 days to assess compliance with the corrective action plan's first milestone targets.

The fee petition stakes — in both the regular hourly billing and EAJA contexts: bank regulatory compliance attorneys representing banks in OCC examination defense and MRA remediation bill hourly to their bank clients. The contemporaneous record is the foundation of every client invoice. When the OCC escalates from an MRA to a formal enforcement proceeding — a cease-and-desist order, civil money penalty proceeding, or removal and prohibition action under 12 U.S.C. § 1818 — and the bank ultimately prevails, the Equal Access to Justice Act, 5 U.S.C. § 504, provides fee-shifting for legal work done in the enforcement defense if the OCC's position was not "substantially justified" under Pierce v. Underwood, 487 U.S. 552 (1988). The EAJA lodestar includes the MRA remediation advisory calls as pre-enforcement investigation time directly connected to the enforcement defense when the attorney can demonstrate that the MRA identified the same practices the enforcement action challenged. The MRA remediation advisory call cycle is the largest and most vulnerable billing gap in that EAJA record.

OCC MRA remediation advisory call types and their timing structure: (a) MRA response letter preparation advisory call (40–55 min) — the OCC issues the draft examination report identifying MRAs 30–45 days after the on-site examination concludes; the attorney calls when the client receives the draft report to advise on the substantive response, the board resolution language, and the corrective action plan structure before the final examination report is issued; this call arrives on the OCC's examination report issuance timeline; (b) Board resolution and corrective action plan submission advisory call (35–50 min) — the bank's compliance team drafts the corrective action plan identifying the specific steps, responsible parties, and milestone dates for MRA remediation; the attorney calls when the compliance team's draft is ready for legal review, typically 15–20 days after the final examination report is issued; arriving when the compliance team is ready, not on the attorney's billing calendar; (c) First-quarter compliance milestone verification advisory call (35–50 min) — the OCC schedules a progress review or interim examination approximately 90 days after the corrective action plan is submitted to assess the bank's completion of first-quarter milestones; the attorney calls 7–10 days before the OCC progress review to confirm that the milestone documentation is sufficient and that any outstanding items are identified; arriving on the OCC's 90-day follow-up calendar; (d) OCC examiner follow-up validation meeting preparation advisory call (30–45 min) — at the 180-day mark, the OCC examiner schedules a second progress review or validation meeting with the bank's compliance officer and management team; the attorney calls when the OCC announces the meeting to prepare the client's compliance representatives for examiner questions and to review the second-quarter milestone documentation; arriving on the OCC's 180-day examination calendar; (e) Supervisory agreement modification or enforcement escalation advisory call (30–45 min) — if the bank fails to meet a corrective action plan milestone, the OCC may issue a warning letter, upgrade the MRA to a Matter Requiring Immediate Attention (MRIA), or initiate a formal supervisory agreement or enforcement action; the attorney calls when the OCC issues any escalation signal; arriving on the OCC's escalation calendar with no advance notice to the attorney; (f) MRA closure confirmation and next examination cycle preparation advisory call (25–35 min) — when the OCC determines that the MRA has been satisfactorily addressed — typically 12–18 months after the original MRA in a community bank examination cycle — the OCC confirms closure in the subsequent examination report; the attorney calls when the client receives the closure notification to discuss residual supervisory concerns and the next examination cycle preparation; arriving on the OCC's next examination report issuance timeline; (g) EAJA fee petition lodestar documentation support call (20–30 min) — if the enforcement proceeding concludes in the bank's favor and the EAJA petition is being prepared, the attorney calls with the client's records team to compile the contemporaneous billing record for the fee petition affidavit, cross-referencing the examination report, corrective action plan submissions, and OCC correspondence dates with the billing entries; arriving when the fee petition preparation begins.

Arithmetic: 5 active OCC MRA clients in the remediation phase × 7 advisory calls (4 substantive remediation and milestone calls, 2 OCC follow-up and escalation coordination calls, 1 EAJA fee petition support call) × 40 min average × 55% untracked = 12.8 untracked hours = $5,760–$9,600/year at $450–$750/hr.

The Welch v. Metropolitan Life Insurance Co., 480 F.3d 942 (9th Cir. 2007), temporal clustering inference applies to the OCC MRA billing pattern in a specific way that distinguishes it from other practice areas: the examination cycle generates advisory call bursts at five predictable intervals — examination report issuance (month 0), corrective action plan submission (month 1), first progress review (month 3), second progress review (month 6), and MRA closure (month 14–18) — with 45–90 day silences between each burst. This temporal distribution (short burst, long gap, burst, long gap, burst, very long gap, final burst) is the structural fingerprint of the OCC examination cycle calendar, not of the attorney's billing system. When five MRA clients all received their OCC examinations in the same rolling examination window — as community banks in the same OCC district often do when the OCC conducts regional examination campaigns — the attorney's billing record shows five clients each generating the same five-burst pattern in the same quarterly windows. The defendant's billing expert can identify the examination calendar as the common source of the temporal distribution without access to any confidential OCC examination communications, using only the OCC's published examination cycle guidance and the bank's publicly filed correspondence with the OCC. Under Role Models America, Inc. v. Brownlee, 353 F.3d 962 (D.C. Cir. 2004), a percentage reduction applied to all entries exhibiting the examination-cycle temporal clustering pattern can eliminate far more than the 12.8 untracked hours — and under Missouri v. Jenkins, 491 U.S. 274 (1989), that reduction extends to the EAJA fee petition preparation entries themselves when the merits record shows the pattern.

The FDIC Section 8(b) consent order compliance monitoring call cycle: 11.0 untracked hours = $4,950–$8,250/year

FDIC Section 8(b) of the Federal Deposit Insurance Act, 12 U.S.C. § 1818(b), authorizes the FDIC to enter into written agreements and consent orders with insured depository institutions requiring the bank to take or refrain from specified actions to address safety and soundness or consumer compliance deficiencies identified in an FDIC examination. Consent orders are public documents, published on the FDIC's website, that establish specific compliance requirements — capital maintenance ratios, credit concentration limits, board oversight improvements, management changes, consumer compliance program enhancements — and set mandatory compliance monitoring obligations including quarterly attestations, annual compliance reports, and ongoing reporting to the FDIC regional director.

The compliance monitoring call cycle generated by FDIC consent orders is structurally distinct from OCC MRA remediation: rather than five milestone bursts spread over 14–18 months, the FDIC consent order generates a steady-state quarterly and annual compliance calendar that continues for the duration of the consent order — typically 2–5 years from entry. An attorney with three active consent order clients maintains a perpetual compliance monitoring call cycle in which eight categories of advisory calls arrive on the FDIC's own compliance calendar throughout each calendar year.

FDIC consent order compliance monitoring call types and their timing structure: (a) Quarterly compliance attestation preparation advisory call (50–65 min) — Section 8(b) consent orders routinely require the bank's board of directors to review compliance with each consent order provision at each quarterly board meeting and to submit a compliance certification to the FDIC regional director within 15 days of the review; the attorney calls 10–14 days before each quarter-end to review the compliance status report, identify any areas of partial compliance or documentation gaps, and advise on the attestation language; arriving four times per year on the consent order's quarterly compliance calendar, regardless of the litigation or business calendar; (b) Annual comprehensive compliance report advisory call (45–60 min) — many FDIC consent orders require an annual comprehensive compliance report prepared by the bank's compliance department and reviewed by outside counsel, submitted to the FDIC regional director by a specified annual deadline; the attorney calls when the compliance team's draft is ready for legal review; arriving once per year on the consent order's anniversary; (c) External compliance reviewer coordination call (40–55 min) — consent orders involving elevated risk (management deficiencies, significant consumer compliance violations) often require the bank to engage an independent external compliance reviewer to assess compliance and report directly to the FDIC; the attorney calls when the external reviewer issues a preliminary findings report to assess privilege considerations, legal sufficiency of the findings, and any disclosures that implicate legal advice; arriving on the external reviewer's assessment and report schedule; (d) FDIC regional director monitoring conference preparation advisory call (35–50 min) — the FDIC's regional director schedules periodic monitoring conference calls or meetings with the bank's board chair, CEO, and compliance officer to review consent order compliance progress; the attorney calls when the FDIC announces the monitoring conference to prepare the bank's representatives and to identify any agenda items that require legal strategy input; arriving on the FDIC's monitoring calendar; (e) Consent order modification or termination petition advisory call (35–50 min) — when the bank has demonstrated sustained compliance with all consent order provisions for a sufficient period, the bank may petition the FDIC for consent order modification (reducing certain requirements as risk declines) or full termination; the attorney calls when the compliance team has assembled the compliance documentation to advise on the petition strategy and timing; arriving when the compliance team's documentation is ready; (f) FDIC enforcement escalation early warning advisory call (40–55 min) — if the FDIC's quarterly review or compliance monitoring reveals a shortfall — a covenant breach, a missed compliance report deadline, or a regulatory examination finding that the consent order compliance program is inadequate — the FDIC's regional director may issue a compliance warning letter before escalating to a Section 8(b) cease-and-desist proceeding or Section 8(e) removal proceeding; the attorney calls when the client receives the compliance warning letter; arriving on the FDIC's escalation calendar; (g) Section 8(i) civil money penalty advisory call (30–45 min) — the FDIC may impose civil money penalties under Section 8(i) of the Federal Deposit Insurance Act, 12 U.S.C. § 1818(i), for knowing violations of written agreements and consent orders; the attorney calls when the FDIC issues a civil money penalty notice or initiates a penalty proceeding; arriving on the FDIC's enforcement action calendar; (h) EAJA lodestar documentation and fee petition support call (20–30 min) — if the bank prevails in an FDIC Section 8 proceeding and an EAJA petition is being prepared, the attorney calls with the client's records team to compile the contemporaneous billing record; arriving when the fee petition preparation begins.

Arithmetic: 3 active FDIC consent order clients in the compliance monitoring phase × 8 advisory calls × 50 min average × 55% untracked = 11.0 untracked hours = $4,950–$8,250/year at $450–$750/hr.

The FDIC quarterly attestation calendar creates the most mechanically regular temporal clustering pattern in bank regulatory compliance billing — more predictable than the OCC examination cycle and more concentrated than the Federal Reserve SR letter milestone calendar. The attorney knows at the outset of the consent order engagement when every quarterly attestation deadline falls: a consent order entered on January 15 requires attestation submissions by mid-April, mid-July, mid-October, and mid-January of each year for the full 2–5 year duration. An attorney with three consent order clients — each with slightly different entry dates but all on quarterly attestation calendars — generates a billing record with 12 quarterly attestation preparation entries per year (4 per client × 3 clients), clustered in the two-week windows preceding each quarter-end. The Welch inference applied to this pattern is straightforward: the temporal distribution of entries tracks the quarterly compliance calendar with mechanical precision; the same duration range appears in each quarterly cluster; the subject-matter descriptions all reference consent order attestation. A billing expert does not need to demonstrate that any individual entry was reconstructed — only that the portfolio-wide quarterly clustering pattern is inconsistent with contemporaneous per-call logging at the entry-specificity level the Hensley framework requires for EAJA petitions.

The Federal Reserve SR letter implementation advisory call cycle: 9.2 untracked hours = $4,140–$6,900/year

Federal Reserve Supervision and Regulation letters (SR letters) communicate supervisory expectations for bank holding companies, financial holding companies, state member banks, and U.S. branches and agencies of foreign banking organizations supervised by the Federal Reserve. Unlike OCC or FDIC examinations that result in formal written findings (examination reports with MRAs, or Section 8(b) formal orders), SR letters establish supervisory policy that the Federal Reserve applies in evaluating examination findings. SR 11-7 (Guidance on Model Risk Management, April 4, 2011) and SR 13-19 (Guidance on Managing Outsourcing Risk, December 5, 2013) are among the most consequential SR letters for bank holding companies because they set detailed expectations for model inventory, model validation, model governance committee oversight, and vendor management that many bank holding companies did not fully implement in their first examination cycle after the guidance was issued.

When the Federal Reserve's examination team — the Large Institution Supervision Coordinating Committee (LISCC) program for the largest bank holding companies, or regional examination teams for state member banks and smaller bank holding companies — identifies SR letter implementation gaps during an annual or biennial examination, it issues a supervisory letter or commitment letter to the bank holding company's board of directors. These commitment letters are not formal consent orders, but they carry the same enforcement escalation risk: failure to meet the commitment letter's remediation milestones can trigger escalation to a written agreement or formal cease-and-desist order under 12 U.S.C. § 1818. The attorney's advisory calls arrive at each commitment letter milestone on the Federal Reserve's remediation calendar.

Federal Reserve SR letter implementation advisory call types and their timing structure: (a) Supervisory letter receipt and initial remediation scope advisory call (40–55 min) — the Federal Reserve examination team issues a supervisory letter identifying deficiencies relative to SR letter guidance; the attorney calls when the client receives the supervisory letter to advise on the scope of the findings, the commitment letter remediation plan structure, and the board-level commitments required; arriving on the Federal Reserve's examination cycle timeline; (b) Commitment letter remediation plan drafting and submission advisory call (35–50 min) — the Federal Reserve requires the bank holding company to submit a written commitment letter from the board of directors with a specific remediation plan and milestone timeline; the attorney calls when the client's legal and compliance teams have drafted the commitment letter to review for legal sufficiency and enforceability of the milestone language; arriving 30–45 days after the supervisory letter when the remediation plan is ready; (c) Model risk management (SR 11-7) remediation milestone review advisory call (30–45 min) — SR 11-7 implementation projects generate specific milestone advisory calls as the bank's model risk management team completes the model inventory, model validation backlogs, and governance committee structure enhancements required by the commitment letter; the attorney calls when the model risk team reports a milestone completion requiring legal review of the documentation for Federal Reserve submission; arriving on the model risk team's project milestone schedule; (d) Federal Reserve LISCC or regional examination team progress review meeting preparation advisory call (35–50 min) — the Federal Reserve examination team schedules mid-cycle progress review meetings to assess commitment letter compliance; the attorney calls when the Federal Reserve announces a progress review meeting to prepare the client's senior management and board compliance committee for examiner questions; arriving on the Federal Reserve's examination calendar; (e) Enforcement escalation and written agreement advisory call (30–45 min) — if the commitment letter's milestones are not met, the Federal Reserve may escalate to a formal written agreement or cease-and-desist order under 12 U.S.C. § 1818(b); the attorney calls when the Federal Reserve signals potential escalation through a second supervisory letter or an adverse examination finding; arriving on the Federal Reserve's enforcement calendar; (f) Commitment letter closure and next examination cycle preparation advisory call (25–35 min) — when the Federal Reserve examination team determines that the SR letter deficiencies have been satisfactorily remediated and the commitment letter obligations have been discharged, the supervision team issues a closure notification; the attorney calls when the client receives the closure to discuss residual supervisory expectations and the next examination preparation; arriving on the Federal Reserve's next examination report timing.

Arithmetic: 4 active Federal Reserve SR letter clients in the commitment letter remediation phase × 6 implementation advisory calls × 42 min average × 55% untracked = 9.2 untracked hours = $4,140–$6,900/year at $450–$750/hr.

The Federal Reserve commitment letter advisory call cycle generates a billing pattern distinct from both the OCC examination cycle and the FDIC quarterly attestation calendar: the SR letter implementation project is milestone-driven rather than calendar-driven, meaning that the timing between advisory calls depends on the bank holding company's internal project completion pace rather than a fixed external deadline. This makes the Federal Reserve billing gap's temporal distribution less mechanically predictable than the FDIC quarterly attestation pattern — but it also makes it more vulnerable to the Welch inference in a different way. When the attorney's billing record shows Federal Reserve SR letter implementation advisory entries arriving in irregular bursts (model inventory milestone completion, model validation backlog reduction completion, governance committee formation, progress review preparation, closure), each separated by 45–120 day silences that correspond exactly to the bank holding company's internal project milestones rather than to any billing calendar the attorney controls, the temporal distribution is driven entirely by the client's project management schedule — not by the attorney's per-call contemporaneous observation of what work was done on what day. The defendant's billing expert can obtain the bank holding company's commitment letter milestone submissions from the Federal Reserve (if they were made public in an enforcement order or annual report), cross-reference the milestone dates with the billing entries, and demonstrate that every advisory call entry falls within 5 business days of a publicly documented commitment letter milestone — eliminating the statistical possibility that the entries were logged contemporaneously at the per-call level rather than reconstructed from the milestone calendar.

The three-regulator billing gap compounds when an attorney represents a bank holding company that simultaneously has OCC MRAs (for the national bank subsidiary), FDIC consent order compliance obligations (for the bank's FDIC-supervised deposits), and Federal Reserve SR letter commitment letters (for the holding company's model risk and outsourcing programs). In this configuration — common for mid-size bank holding companies operating national bank subsidiaries with FDIC-insured deposits — the attorney maintains a billing calendar in which OCC examination-cycle call bursts, FDIC quarterly attestation call bursts, and Federal Reserve milestone advisory call bursts arrive in overlapping but non-synchronized waves throughout the calendar year. The total billing gap across all three federal regulators is 33.0 untracked hours = $14,850–$24,750/year — and the three-regulator temporal clustering pattern across a single client's billing record is the most complex and systematic external-schedule driving force in any fee petition context.

Three diagnostics for bank regulatory compliance billing gap identification

Diagnostic 1 — OCC MRA phase-transition log audit. For your most recent OCC MRA client, obtain the dates of the five formal phase-transition documents the OCC has issued: the draft examination report identifying the MRA, the final examination report, the OCC's acknowledgment of the corrective action plan submission, the first progress review findings, and the MRA closure notification (or the most recent progress review if the matter is ongoing). For each phase-transition document date, check whether a billing entry of 30+ minutes appears within 5 business days. If any phase-transition date has no proximate billing entry, the OCC MRA advisory call for that phase is running at zero capture — and if this pattern applies to two or more MRA clients examined in the same OCC district examination window, the examiner calendar cross-correlation identifies the temporal clustering as systematic across your OCC regulatory practice.

Diagnostic 2 — FDIC quarterly attestation capture rate. For your most recent FDIC consent order client, identify the four quarterly attestation submission deadlines (typically 15 days after each quarter-end board meeting). For each quarterly deadline, check whether a billing entry of 40+ minutes referencing the consent order, attestation, compliance review, or FDIC reporting appears within 14 calendar days of the deadline. If any quarter has no proximate billing entry, the quarterly attestation preparation advisory call ran at zero capture for that quarter. If three or more quarters across two consecutive calendar years show the same gap pattern, the FDIC quarterly attestation calendar is driving a systematic quarterly billing gap — and the Welch temporal clustering inference can use the correlated quarterly gaps across multiple clients to demonstrate portfolio-wide reconstruction.

Diagnostic 3 — Federal Reserve SR letter milestone correlation audit. For your most recent Federal Reserve commitment letter client, identify the milestone completion dates from the commitment letter Exhibit A (the milestone tracking table submitted to the Federal Reserve). For each milestone completion date, check whether a billing entry of 25+ minutes referencing the SR letter, commitment letter, model risk, outsourcing risk, or Federal Reserve appears within 5 business days. If the billing entries systematically appear within a narrow window after each publicly documented milestone date — and the gaps between entries correspond precisely to the gaps between milestone completions rather than to any uniform billing calendar — the Federal Reserve milestone calendar is the sole temporal driver of your billing pattern, making the contemporaneous-vs.-reconstructed distinction the central issue in any EAJA fee petition based on that record.

How ClaimHour fits bank regulatory compliance practice

If your OCC practice generates MRA response preparation advisory calls when the OCC issues the draft examination report at 3:45 p.m. on a Tuesday, your FDIC practice generates quarterly attestation preparation calls in the two weeks before each quarter-end on the FDIC's compliance calendar, and your Federal Reserve practice generates SR 11-7 model validation milestone advisory calls when the client's model risk team closes the backlogs on its own project timeline — and none of those calls consistently appears in your billing system because they all arrived on someone else's schedule — ClaimHour was built for that gap. The passive capture logs every call (iOS call metadata: duration, timestamp, direction, not content), every email advisory session, and every document review session. The 2-minute evening digest surfaces each unmatched call for matter attribution. No audio, no call content, no email bodies stored. Privilege is preserved under ABA Formal Opinion 512. At $450–$750/hr, 33.0 additional tracked hours per year = $14,850–$24,750 of previously unlogged time before the EAJA fee petition — and the contemporaneous per-call records that eliminate the Welch examination-cycle temporal clustering pattern and the Hensley percentage reduction that applies to the entire billing record when the pattern is identified in the OCC, FDIC, and Federal Reserve advisory call phases simultaneously.

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