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Vertical guide · Updated June 2026

Bank regulatory compliance attorney time tracking: OCC safety and soundness examination advisory calls, FDIC problem institution special examination advisory, and Federal Reserve BHC holding company supervisory advisory

Bank regulatory compliance law solo attorneys advising on Office of the Comptroller of the Currency (OCC) national bank safety and soundness examinations under 12 U.S.C. § 481 and 12 C.F.R. Part 30, FDIC risk management examinations and Prompt Corrective Action (PCA) proceedings under 12 U.S.C. § 1820(b) and 12 U.S.C. § 1831o, and Federal Reserve Bank Holding Company (BHC) consolidated supervision examinations under 12 U.S.C. § 1844(c) — including CAMELS rating advisory, Matters Requiring Attention (MRA) and Matters Requiring Immediate Attention (MRIA) remediation, Troubled Debt Restructuring (TDR) advisory, DFAST/CCAR capital planning advisory, and formal enforcement action (consent order, formal agreement, cease-and-desist) advisory under 12 U.S.C. § 1818 — generate three billing-gap sources driven by the OCC's examination calendar, the FDIC's regulatory examination timeline, and the Federal Reserve's BHC supervision examination calendar: OCC safety and soundness examination advisory calls on the OCC's examination calendar (5 clients × 6 calls × 38 min × 55% untracked = 10.45 hours ≈ 10.5 hours = $4,725–$7,088/year at $450–$675/hr), FDIC problem institution special examination advisory calls on the FDIC's regulatory examination timeline (4 clients × 5 calls × 35 min × 55% = 6.42 hours ≈ 6.4 hours = $2,880–$4,320/year), and Federal Reserve BHC holding company examination advisory calls on the Federal Reserve's examination calendar (3 clients × 5 calls × 32 min × 55% = 4.4 hours = $1,980–$2,970/year). For a bank regulatory compliance solo practice, the annual billing gap is $9,585–$14,378.

TL;DR

ClaimHour captures every OCC management interview preparation call that arrives when OCC examiners schedule interviews on their examination calendar, every FDIC Troubled Debt Restructuring advisory call that arrives when FDIC examination staff shares preliminary classification findings on their examination timeline, and every Federal Reserve SR letter compliance review advisory call that arrives on the Federal Reserve's examination schedule — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.

OCC safety and soundness examination advisory: calls on the OCC's examination calendar

OCC national bank examinations under 12 U.S.C. § 481 (OCC's authority to examine every national bank as often as the Comptroller deems necessary) and 12 C.F.R. Part 30 (OCC safety and soundness standards) follow the OCC's examination scheduling calendar, which the OCC sets unilaterally based on the bank's CAMELS composite rating, asset size, and the OCC's supervisory strategy. OCC examination teams send pre-examination information requests listing specific document categories — loan portfolio schedules, board minutes, audit reports, compliance management system documentation, and capital adequacy analysis — and schedule management interviews with the bank's CEO, CFO, CRO, Chief Compliance Officer, and board risk committee chair on the examination team's interview calendar, not on any date controlled by the bank or its counsel. When OCC examiners identify preliminary concerns during the examination, they communicate those concerns through pre-report exit meetings and preliminary MRA notifications — each of which triggers an immediate attorney advisory call arriving on the OCC's examination communication timeline. For national banks undergoing OCC safety and soundness examinations, the typical 6–8 week on-site examination generates advisory calls at six distinct phases of the examination process, each arriving on the OCC examination team's scheduling calendar.

Six OCC safety and soundness examination advisory call types: (1) OCC pre-examination document request scope advisory call — advising on the scope of the OCC's pre-examination information request, the privilege review for internal audit reports and board risk committee minutes, and the document production methodology for transaction data and loan file samples (25–40 min) — arrives when the OCC examination team sends the pre-examination information request letter on the OCC's examination scheduling calendar; (2) OCC management interview preparation call per bank officer — advising the CEO, CFO, CRO, CCO, or board risk committee chair scheduled by OCC examiners for a management interview on the examiner's interview calendar (28–38 min per officer); (3) OCC capital adequacy assessment review advisory call — advising on the OCC examiners' capital component findings under the CAMELS Capital assessment framework, including Tier 1 capital ratio, Total Capital ratio, leverage ratio, and capital adequacy under OCC's capital guidelines (12 C.F.R. Parts 3, 6) (28–38 min) — arrives when OCC examination staff shares preliminary capital assessment findings on the examination timeline; (4) OCC Matters Requiring Attention remediation plan advisory call — advising on the corrective action plan for MRA findings identified in the examination report, including required remediation timelines and periodic progress reporting to OCC supervisory staff (25–35 min) — arrives when the OCC issues the final examination report with MRA findings on the OCC's reporting calendar; (5) OCC supervisory letter response advisory call — advising on the required management response to an OCC supervisory letter issued under 12 C.F.R. § 5.51 that identifies examination findings requiring formal management acknowledgment (28–38 min) — arrives when the OCC sends the supervisory letter on the OCC's supervisory communication timeline; (6) OCC formal enforcement action advisory call — advising on the terms of a formal agreement, consent order, or cease-and-desist order proposed under 12 U.S.C. § 1818(b)–(c) (30–40 min) — arrives when the OCC presents the proposed formal enforcement action on the agency's enforcement timeline. At 55% untracked: 5 clients × 6 advisory calls × 38 min × 55% = 10.45 hours ≈ 10.5 hours = $4,725–$7,088/year at $450–$675/hr.

FDIC problem institution special examination advisory: calls on the FDIC's examination timeline

FDIC risk management examinations of state nonmember banks under 12 U.S.C. § 1820(b) assess bank safety and soundness using the CAMELS rating framework, and FDIC problem institution examinations — triggered when a bank's CAMELS composite rating is downgraded to 3, 4, or 5 — intensify the examination's frequency and scope. FDIC problem institution special examinations address Troubled Debt Restructuring (TDR) classification under ASC 310-40 (the accounting standard for restructured loans and the FDIC's TDR guidance from the Financial Institutions Examination Council), capital adequacy under the FDIC's Prompt Corrective Action (PCA) framework (12 U.S.C. § 1831o), and the FDIC's consent order and PCA directive authority under 12 U.S.C. § 1818(b) — all proceeding on the FDIC's regulatory examination timeline, which the FDIC sets based on the bank's supervisory condition, not on the bank's or attorney's scheduling preferences. FDIC TDR review calls arrive when the FDIC examination team schedules its loan classification conference on the examination calendar; PCA capital restoration plan review calls arrive when the FDIC determines that the bank's capital has fallen below a PCA capital category threshold and requires a formal capital restoration plan under 12 U.S.C. § 1831o(e); consent order negotiation calls arrive when FDIC enforcement staff presents proposed consent order terms on the agency's enforcement timeline. The unpredictability of FDIC problem institution examination scheduling — which can be triggered by sudden loan portfolio deterioration at any point during the examination cycle — means that advisory calls can arrive with little advance notice on the FDIC's accelerated examination calendar.

Five FDIC problem institution special examination advisory call types: (1) FDIC special examination document collection advisory call — advising on the scope of the FDIC examination team's targeted request for loan portfolio schedules, classified asset documentation, allowance for loan and lease losses (ALLL) methodology documentation, and interest rate risk measurement models (25–35 min) — arrives when the FDIC examination team requests targeted documentation on the FDIC's examination timeline; (2) FDIC Troubled Debt Restructuring advisory call — advising on the FDIC examiners' TDR classification analysis under ASC 310-40, including concession analysis, borrower financial difficulty assessment, and the bank's TDR accounting methodology (28–38 min) — arrives when FDIC examination staff shares preliminary TDR classification findings on the examination calendar; (3) FDIC capital plan review advisory call — advising on the required contents of the bank's capital restoration plan under 12 U.S.C. § 1831o(e) and the FDIC's assessment of the plan's adequacy and the parent holding company's guarantee obligations (28–38 min) — arrives when the FDIC examination team reviews the capital restoration plan submission on the FDIC's PCA review timeline; (4) FDIC consent order negotiation advisory call — advising on the proposed consent order terms under 12 U.S.C. § 1818(b), including the scope of the enforcement commitments, civil money penalty amounts, the required compliance committee and compliance plan submission, and periodic progress reporting obligations to FDIC supervisory staff (30–40 min) — arrives when FDIC enforcement staff presents the proposed consent order on the agency's enforcement timeline; (5) FDIC Prompt Corrective Action directive advisory call — advising on the implications of a PCA directive under 12 U.S.C. § 1831o(f) or a notice of intent to issue a PCA directive, including mandatory PCA restrictions on dividends, management fees, and asset growth, and the bank's options for challenging the PCA directive under 12 U.S.C. § 1831o(h) (25–35 min) — arrives when the FDIC issues the PCA directive or notice on the FDIC's PCA implementation calendar. At 55% untracked: 4 clients × 5 calls × 35 min × 55% = 6.42 hours ≈ 6.4 hours = $2,880–$4,320/year at $450–$675/hr.

Federal Reserve BHC holding company examination advisory: calls on the Federal Reserve's examination calendar

Federal Reserve inspection of bank holding companies under 12 U.S.C. § 1844(c) (the Board's authority to examine BHCs and their subsidiaries) and the Federal Reserve's consolidated supervision framework follows the Federal Reserve's examination calendar, which the Federal Reserve sets based on the BHC's supervisory rating (RFI/C(D) rating: Risk Management, Financial Condition, Impact, Composite with Depository Institution rating), asset size, and the complexity of the BHC's nonbank activities. The Federal Reserve's consolidated BHC supervision framework integrates BHC corporate governance assessment under SR 12-17 (Federal Reserve guidance on effective boards of directors), capital planning assessment under the Dodd-Frank stress testing (DFAST) requirements for BHCs with $100 billion or more in total assets (12 U.S.C. § 5365(i)) and the Federal Reserve's stress testing expectations for smaller BHCs, and SR letter compliance review (Federal Reserve supervisory guidance letters impose ongoing compliance expectations for all BHCs, including SR 11-7 on model risk management, SR 15-18 on the large financial institution rating system, and SR 21-19 on climate-related financial risk management). Federal Reserve examination staff schedules BHC governance reviews, capital planning document requests, and SR letter compliance assessments on the Federal Reserve's examination calendar — with supervisory letters and formal enforcement action advisory calls arriving when the Federal Reserve issues supervisory communications on the Federal Reserve's supervisory timeline.

Five Federal Reserve BHC holding company examination advisory call types: (1) Federal Reserve BHC corporate governance review advisory call — advising on the Federal Reserve examination staff's review of BHC board governance under SR 12-17, including board independence requirements, board committee structure (audit, risk, compensation committees), and management reporting and escalation frameworks (25–35 min) — arrives when the Federal Reserve examination team requests board minutes, committee charters, and governance documentation on the Federal Reserve's examination calendar; (2) Federal Reserve DFAST/CCAR capital planning advisory call — advising on the Federal Reserve examination staff's review of the BHC's capital planning process, internal stress scenario design methodology, capital adequacy projections across baseline and adverse scenarios, and capital distribution policy (28–38 min) — arrives when the Federal Reserve examination staff reviews the BHC's capital plan submission on the Federal Reserve's capital assessment timeline; (3) Federal Reserve SR letter compliance review advisory call — advising on the BHC's compliance with specific SR letters identified by the Federal Reserve examination staff as requiring enhanced compliance, including SR 11-7 (model risk management governance), SR 15-18 (large financial institution rating system governance expectations), and the Federal Reserve's consumer compliance expectations (25–35 min) — arrives when the Federal Reserve examination staff assesses SR letter compliance on the examination team's review schedule; (4) Federal Reserve supervisory letter response advisory call — advising on the required management response to a Federal Reserve supervisory letter identifying examination findings and requiring a formal BHC board and management response with a remediation plan and timeline (28–38 min) — arrives when the Federal Reserve issues the supervisory letter on the Federal Reserve's supervisory communication timeline; (5) Federal Reserve BHC formal enforcement action advisory call — advising on the terms of a written agreement, cease-and-desist order, or civil money penalty under 12 U.S.C. § 1818 and the Federal Reserve's enforcement authority under 12 U.S.C. § 1847 (BHC Act civil money penalty authority) (30–40 min) — arrives when the Federal Reserve presents the proposed formal enforcement action on the Federal Reserve's enforcement calendar. At 55% untracked: 3 clients × 5 calls × 32 min × 55% = 4.4 hours = $1,980–$2,970/year at $450–$675/hr.

How ClaimHour fits bank regulatory compliance practice

If you advise national banks on OCC safety and soundness examinations with management interview preparation calls arriving when OCC examiners schedule on their examination calendar, FDIC problem institution clients on TDR classification advisory and PCA capital restoration plan review advisory calls arriving on the FDIC's accelerated examination timeline, and BHC clients on Federal Reserve DFAST/CCAR capital planning and SR letter compliance review advisory calls arriving on the Federal Reserve's consolidated supervision examination calendar — and your invoices consistently understate the OCC MRA remediation plan advisory calls that arrive on the OCC's reporting calendar, the FDIC consent order negotiation calls that arrive on the FDIC enforcement staff's timeline, and the Federal Reserve supervisory letter response advisory calls that arrive on the Federal Reserve's supervisory communication timeline — ClaimHour was built for that gap.

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Related questions

How do OCC safety and soundness examination advisory calls generate billing gaps on the OCC's examination calendar?

OCC national bank examinations under 12 U.S.C. § 481 and 12 C.F.R. Part 30 proceed on the OCC's examination scheduling calendar: OCC examiners send document requests, schedule management interviews on their interview calendar, issue MRA and MRIA findings in the examination report, and present formal enforcement actions — all on the OCC's examination timeline, not on the bank's or attorney's calendar. Six advisory call types: OCC pre-examination document request scope advisory call (25–40 min), OCC management interview preparation call per bank officer (28–38 min), OCC CAMELS capital adequacy assessment review advisory call (28–38 min), OCC MRA remediation plan advisory call (25–35 min), OCC supervisory letter response advisory call (28–38 min), and OCC formal enforcement action advisory call (30–40 min). At 55% untracked: 5 clients × 6 advisory calls × 38 min × 55% = 10.45 hours ≈ 10.5 hours = $4,725–$7,088/year at $450–$675/hr.

How do FDIC problem institution special examination advisory calls generate billing gaps on the FDIC's examination timeline?

FDIC problem institution special examinations address TDR classification under ASC 310-40, capital adequacy under the PCA framework (12 U.S.C. § 1831o), consent order negotiation under 12 U.S.C. § 1818(b), and PCA directive advisory — all proceeding on the FDIC's regulatory examination timeline, which intensifies unpredictably when a bank's CAMELS rating is downgraded. Five advisory call types: FDIC special examination document collection advisory call (25–35 min), FDIC Troubled Debt Restructuring advisory call (28–38 min), FDIC capital plan review advisory call under 12 U.S.C. § 1831o(e) (28–38 min), FDIC consent order negotiation advisory call (30–40 min), and FDIC Prompt Corrective Action directive advisory call (25–35 min). At 55% untracked: 4 clients × 5 calls × 35 min × 55% = 6.42 hours ≈ 6.4 hours = $2,880–$4,320/year at $450–$675/hr.

How do Federal Reserve BHC holding company examination advisory calls generate billing gaps on the Federal Reserve's examination calendar?

Federal Reserve BHC consolidated supervision examinations under 12 U.S.C. § 1844(c) follow the Federal Reserve's examination calendar, with examination staff scheduling BHC corporate governance reviews under SR 12-17, DFAST/CCAR capital planning assessments under 12 U.S.C. § 5365(i), SR letter compliance reviews, and supervisory letter responses on the Federal Reserve's own examination timeline — independent of the bank's or attorney's scheduling preferences. Five advisory call types: Federal Reserve BHC corporate governance review advisory call (25–35 min), Federal Reserve DFAST/CCAR capital planning advisory call (28–38 min), Federal Reserve SR letter compliance review advisory call (25–35 min), Federal Reserve supervisory letter response advisory call (28–38 min), and Federal Reserve BHC formal enforcement action advisory call (30–40 min). At 55% untracked: 3 clients × 5 calls × 32 min × 55% = 4.4 hours = $1,980–$2,970/year at $450–$675/hr.

How does bank regulatory compliance attorney billing differ from other financial regulatory advisory billing?

Standard financial regulatory advisory billing (FINRA broker-dealer examination, SEC investment adviser examination) follows published examination cycles with relatively predictable document request timelines. Bank regulatory compliance attorney billing differs because three independent federal banking regulators drive advisory calls simultaneously on separate examination calendars: the OCC's safety and soundness examination calendar (set unilaterally by OCC examiners with document requests and management interview schedules); the FDIC's risk management examination timeline (which intensifies unpredictably when a bank's CAMELS rating changes and the FDIC schedules problem institution examinations); and the Federal Reserve's BHC consolidated supervision examination calendar (which the Federal Reserve sets independently for BHC governance, DFAST/CCAR capital planning, and SR letter compliance reviews). For a BHC with multiple bank subsidiaries, the attorney may simultaneously manage advisory calls on three independent federal banking regulator examination calendars. The combined annual billing gap for a bank regulatory compliance solo practice is $9,585–$14,378/year — 21.3 untracked hours.

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