ClaimHour

Vertical guide · Updated June 2026

Securities regulation attorney time tracking: FINRA broker-dealer examination advisory, SEC investment adviser examination advisory, and FINRA Regulation Best Interest compliance advisory

Securities regulation attorneys advising FINRA-member broker-dealers on cycle examinations under FINRA Rule 3110, 15 U.S.C. § 78o, SEC-registered investment advisers on EXAM examinations under the Investment Advisers Act of 1940, 15 U.S.C. §§ 80b-1 et seq., and broker-dealers on Regulation Best Interest compliance under Exchange Act Rule 15l-1, 17 C.F.R. § 240.15l-1 — whose time records must satisfy the securities regulatory counsel billing documentation standard and the FINRA and SEC examination record-keeping requirement — generate three billing gaps driven by FINRA's examination notification and cycle examination schedule, the SEC's EXAM examination scheduling calendar, and FINRA's regulatory notice publication timeline: FINRA broker-dealer examination advisory calls on the FINRA examination cycle (6 clients × 5 calls × 40 min × 55% untracked = 11.0 hrs = $4,950–$8,250/year at $450–$750/hr), SEC IA examination advisory calls on the SEC examination schedule (4 clients × 4 calls × 35 min × 55% = 5.1 hrs = $2,295–$3,825/year), and FINRA Reg BI compliance advisory calls on the FINRA regulatory notice publication schedule (3 clients × 3 calls × 30 min × 55% = 2.5 hrs = $1,125–$1,875/year). For a securities regulation solo practice, the annual billing gap is $8,370–$13,950.

TL;DR

ClaimHour captures every FINRA cycle examination preparation advisory call that arrives when FINRA issues its examination notification 2–4 weeks before the examination start, every SEC EXAM information request advisory call that arrives on EXAM's examination scheduling calendar, and every FINRA Reg BI regulatory notice advisory call that arrives on FINRA's publication date — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.

FINRA broker-dealer examination advisory: calls on the FINRA examination cycle

FINRA conducts risk-based cycle examinations of FINRA member broker-dealers under FINRA Rule 3110 (supervision) and Exchange Act § 15(b)(4), 15 U.S.C. § 78o(b)(4), with examination frequency based on the member firm's risk profile — ranging from annual examinations for the largest, highest-risk firms to examinations every four years for smaller, lower-risk firms. FINRA's examination prioritization considers the firm's business activities (retail recommendation activity, complex products, cryptocurrency assets), its compliance history, customer complaint patterns, and FINRA's annual examination priorities published each January. The FINRA cycle examination process generates advisory calls on five stages of FINRA's examination timeline: (1) examination notification advisory (when FINRA notifies the member firm of the upcoming examination, typically 2–4 weeks before the on-site examination, with an initial information request covering firm organizational structure, supervisory procedures, financial records, and customer complaint files); (2) document request response advisory (during the examination when FINRA's examination team issues supplemental information requests for specific customer account records, trade surveillance data, or supervisory review documentation, on the examination team's timeline); (3) on-site examination advisory (during the on-site examination week when FINRA examiners conduct interviews and review records on-site, and counsel must be available to advise on examiner inquiries in real time); (4) preliminary findings advisory (after the on-site examination when the examination team informally identifies potential findings before issuing the formal Letter of Caution, Cautionary Action, or Formal Submission for review); and (5) formal examination response advisory (when FINRA issues its cycle examination findings and counsel must advise on the response strategy, the remediation plan, and the risk of FINRA referral to the SEC or a formal disciplinary proceeding). Advisory calls at each stage arrive on FINRA's examination scheduling timeline — not on any deadline the broker-dealer's counsel controls.

Five FINRA cycle examination advisory call types that arrive on the FINRA examination timeline: (1) FINRA examination notification and initial information request advisory call — arrives when FINRA notifies the member firm of the upcoming cycle examination and issues its initial information request, and counsel must advise the firm's compliance staff on the examination scope, attorney-client privilege considerations in the examination context under Exchange Act § 15(b)(4), and document preservation obligations (40–50 min) — on FINRA's examination notification timeline; (2) FINRA examination document production advisory call — arrives when FINRA issues supplemental information requests during the examination for specific customer account records, surveillance data, or supervisory procedures (35–45 min) — on the examination team's production request timeline; (3) FINRA on-site examination advisory call — arrives during the on-site examination week when FINRA examiners conduct interviews of compliance and supervisory staff, and counsel must advise on the scope of FINRA's examination authority under FINRA Rule 8210 and how to respond to examiner inquiries (38–48 min); (4) preliminary findings advisory call — arrives after the on-site examination when the examination team informs the member firm of preliminary concerns — such as supervision deficiencies under FINRA Rule 3110, suitability issues under FINRA Rule 2111, or anti-money laundering program deficiencies under FINRA Rule 3310 — and counsel must advise on the merits of the preliminary findings and the remediation options before the formal findings letter (35–45 min); (5) formal findings and disciplinary referral advisory call — arrives when FINRA issues the cycle examination findings letter, and counsel must advise on the written response, the remediation timeline, the risk of the findings being used in a FINRA enforcement proceeding under FINRA Rule 9200, and the firm's disclosure obligations for the findings in Form BD on EDGAR (32–42 min) — on FINRA's post-examination review schedule. At 55% untracked: 6 clients × 5 calls × 40 min × 55% = 660 min / 60 = 11.0 hours = $4,950–$8,250/year at $450–$750/hr.

SEC investment adviser examination advisory: calls on the SEC examination schedule

The SEC's Division of Examinations (EXAM) conducts risk-based examinations of SEC-registered investment advisers under the Investment Advisers Act of 1940 (IAA), 15 U.S.C. §§ 80b-1 et seq., and the Investment Company Act of 1940 for fund advisers, scheduling examinations based on EXAM's annual examination priorities and risk assessment of individual advisers. EXAM's examination prioritization focuses on advisers with elevated risk profiles: advisers that have never been examined, advisers managing private funds, advisers with complex investment strategies, advisers with recent material changes to their business, and advisers identified in EXAM's annual priorities report. The SEC IA examination process generates advisory calls at four stages: (1) initial information request advisory (when EXAM issues the examination notification letter and initial information request, typically requesting compliance policies and procedures, client advisory agreements, Form ADV Part 2 brochures, and trade order records); (2) on-site examination advisory (if EXAM conducts an on-site examination, which arrives on EXAM's scheduling calendar); (3) preliminary deficiency discussions advisory (when EXAM staff informally raises concerns about potential deficiencies in the adviser's compliance program, disclosure practices, or recordkeeping before issuing the formal deficiency letter); and (4) deficiency letter response advisory (when EXAM issues the deficiency letter, which the adviser must respond to within 30 days of issuance on EXAM's post-examination schedule). For advisers managing private funds subject to concurrent SEC Form PF examination scrutiny and EXAM's private fund risk-targeted examination program, advisory calls are generated on two independent examination schedules within the SEC — EXAM's cycle examination schedule and EXAM's private fund risk-targeted examination schedule — in addition to any FINRA examination advisory calls generated by an affiliated broker-dealer.

Four SEC IA examination advisory call types that arrive on EXAM's examination scheduling calendar: (1) EXAM initial information request advisory call — arrives when EXAM issues the examination notification and initial information request letter, and counsel must advise the adviser's compliance staff on the scope of EXAM's information request, how to organize the production of Form ADV, compliance manual, and trade records, and how to assert attorney-client privilege over privileged materials within the examination production (35–45 min) — on EXAM's examination scheduling calendar; (2) EXAM on-site examination advisory call — arrives when EXAM schedules an on-site examination of the adviser's compliance function, and counsel must advise on EXAM's on-site examination procedures, how to handle EXAM staff interviews of compliance and portfolio management personnel, and how to respond to EXAM's real-time requests for additional documentation during the on-site examination (32–42 min); (3) EXAM preliminary deficiency advisory call — arrives when EXAM staff informally identifies potential deficiencies in the adviser's compliance program (such as inadequate Form ADV disclosure of conflicts of interest under IAA § 206, 15 U.S.C. § 80b-6, or incomplete fee offset disclosure), and counsel must advise on the merits of EXAM's preliminary deficiency assessment and the options for addressing the deficiency before the formal deficiency letter (30–40 min); (4) EXAM deficiency letter response advisory call — arrives when EXAM issues the formal examination deficiency letter and counsel must advise on the written response timeline (typically 30 days), the remediation steps, the risk of EXAM referring identified violations to the SEC's Division of Enforcement, and the adviser's disclosure obligations in Form ADV Part 2 regarding the deficiency findings (35–45 min) — on EXAM's post-examination schedule. At 55% untracked: 4 clients × 4 calls × 35 min × 55% = 308 min / 60 = 5.13 hours ≈ 5.1 hours = $2,295–$3,825/year at $450–$750/hr.

FINRA Reg BI compliance advisory: calls on the FINRA regulatory notice publication schedule

FINRA's implementation and ongoing interpretation of Regulation Best Interest (Reg BI) under Exchange Act Rule 15l-1, 17 C.F.R. § 240.15l-1, through FINRA regulatory notices, Frequently Asked Questions (FAQs), and examination findings publications generates compliance advisory calls on three schedules: FINRA's regulatory notice publication schedule (when FINRA publishes new guidance interpreting Reg BI obligations), FINRA's risk-targeted examination schedule (when FINRA conducts Reg BI-specific targeted examinations separate from the cycle examination), and FINRA's examination findings publications schedule (when FINRA publishes aggregated findings from its examination program identifying Reg BI compliance weaknesses across the industry). FINRA regulatory notices interpreting Reg BI — including notices addressing what constitutes a "recommendation" under Rule 15l-1 for digital communication platforms, notices addressing the Reg BI conflict of interest obligation for revenue-sharing arrangements, and notices addressing Form CRS disclosure requirements for dual registrants — are published on FINRA's own publication schedule, not at a time the broker-dealer's counsel controls. When FINRA publishes a new Reg BI regulatory notice, securities regulation counsel must advise broker-dealer compliance staff on the practical implications of the notice on the same day it is published — generating advisory calls across the counsel's book of business simultaneously.

Three FINRA Reg BI compliance advisory call types that arrive on FINRA's publication and examination schedule: (1) FINRA Reg BI regulatory notice publication advisory call — arrives when FINRA publishes a new regulatory notice interpreting Reg BI's care obligation, conflict of interest obligation, or Form CRS disclosure obligation in a way that requires the broker-dealer to modify its compliance procedures, disclosure forms, or supervisory systems, and counsel must advise the compliance staff on the notice's practical implications on FINRA's publication date (30–40 min) — on FINRA's regulatory notice publication schedule; (2) FINRA Reg BI risk-targeted examination advisory call — arrives when FINRA notifies the broker-dealer that it has been selected for a Reg BI-specific risk-targeted examination (separate from the firm's cycle examination), and counsel must advise on the scope of the Reg BI targeted examination, the documentation FINRA will request, and how to characterize the firm's Reg BI compliance program in the examination context (28–38 min) — on FINRA's targeted examination scheduling calendar; (3) FINRA Reg BI examination findings advisory call — arrives when FINRA issues Reg BI-related findings from the cycle examination identifying specific deficiencies in the firm's care obligation documentation, conflict of interest disclosure, or Form CRS updating obligations, and counsel must advise on the findings' merits, the response, and whether the Reg BI deficiencies will be cited in an enforcement referral to the SEC's Division of Enforcement (28–38 min). At 55% untracked: 3 clients × 3 calls × 30 min × 55% = 148.5 min / 60 = 2.48 hours ≈ 2.5 hours = $1,125–$1,875/year at $450–$750/hr.

How ClaimHour fits securities regulation practice

If you advise broker-dealers on FINRA cycle examinations with examination notification preparation calls and on-site examination advisory calls arriving on FINRA's examination scheduling timeline, prepare investment advisers for SEC EXAM examinations with initial information request advisory calls and deficiency letter response advisory calls arriving on EXAM's examination calendar, and advise broker-dealers on Reg BI compliance with FINRA regulatory notice publication advisory calls and Reg BI targeted examination advisory calls arriving on FINRA's publication and examination schedules — and your invoices consistently understate the FINRA preliminary findings advisory calls that arrive before the formal findings letter, the EXAM preliminary deficiency discussions that arrive before the formal deficiency letter, and the FINRA Reg BI examination findings advisory calls that arrive on FINRA's post-examination review schedule — ClaimHour was built for that gap.

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Related questions

How do FINRA broker-dealer examination advisory calls generate billing gaps on the FINRA examination cycle?

FINRA notifies broker-dealers of upcoming cycle examinations 2–4 weeks before the examination start on FINRA's internal risk-prioritization schedule, generating advisory calls at five stages: examination notification and initial information request advisory call (40–50 min), document production advisory call (35–45 min), on-site examination advisory call (38–48 min), preliminary findings advisory call (35–45 min), and formal findings and disciplinary referral advisory call (32–42 min). At 55% untracked: 6 clients × 5 calls × 40 min × 55% = 11.0 hours = $4,950–$8,250/year at $450–$750/hr.

How do SEC investment adviser examination advisory calls generate billing gaps on the SEC examination schedule?

SEC EXAM schedules investment adviser examinations on EXAM's risk-based examination calendar — not announced to the adviser in advance — and examination notification arrives when EXAM decides to initiate the examination on its internal scheduling calendar. Four call types: EXAM initial information request advisory call (35–45 min), EXAM on-site examination advisory call (32–42 min), EXAM preliminary deficiency advisory call (30–40 min), and EXAM deficiency letter response advisory call (35–45 min). At 55% untracked: 4 clients × 4 calls × 35 min × 55% = 5.1 hours = $2,295–$3,825/year at $450–$750/hr.

How do FINRA Reg BI compliance advisory calls generate billing gaps on the FINRA regulatory notice publication schedule?

FINRA publishes Reg BI regulatory notices interpreting the care obligation, conflict of interest obligation, and Form CRS requirements on its own publication schedule, requiring counsel to advise compliance staff on the implications the same day — and FINRA's Reg BI targeted examinations arrive on a separate examination scheduling calendar from the cycle examination. Three call types: FINRA Reg BI regulatory notice publication advisory call (30–40 min), FINRA Reg BI risk-targeted examination advisory call (28–38 min), and FINRA Reg BI examination findings advisory call (28–38 min). At 55% untracked: 3 clients × 3 calls × 30 min × 55% = 2.5 hours = $1,125–$1,875/year at $450–$750/hr.

How does securities regulation attorney billing differ from securities litigation attorney billing?

Securities litigation billing follows court scheduling orders set at the outset of the case. Securities regulation attorney billing differs because FINRA examination, SEC examination, and FINRA regulatory notice publication all drive advisory calls on externally-controlled schedules — FINRA cycle examination calls arrive on FINRA's examination notification timeline, SEC EXAM calls arrive on EXAM's scheduling calendar, and Reg BI advisory calls arrive on FINRA's publication date. The combined annual billing gap is 11.0 + 5.1 + 2.5 = 18.6 hours = $8,370–$13,950/year at $450–$750/hr.

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