Does ClaimHour capture whistleblower coordination work across multiple agencies?

A single whistleblower matter can involve SEC, CFTC, DOJ, IRS, and foreign regulators simultaneously — each with different submission timelines, investigation staff, and coordination requirements. For a matter involving securities fraud with FCPA violations and potential tax evasion, the attorney may coordinate with the SEC's Office of the Whistleblower, a DOJ Criminal Division AUSA, a DOJ Civil Division attorney, and an IRS Whistleblower Office contact across a 3–5 year investigation period. ClaimHour captures each call at its actual duration with the counterparty identified — so the billing record shows the complete multi-agency coordination sequence, and the attorney can calculate the actual hours invested across all agency tracks when the case resolves and the contingency fee is earned.

Vertical guide · Updated June 2026

Whistleblower attorney time tracking: SEC/CFTC tip preparation, FCA investigation period, and multi-agency seal coordination

Q: How are whistleblower attorneys compensated, and why does the billing record matter if there is no hourly fee?

SEC and CFTC whistleblower awards under Dodd-Frank (15 U.S.C. § 78u-6 for SEC; 7 U.S.C. § 26 for CFTC) are paid by the government directly to the whistleblower — 10–30% of sanctions exceeding $1 million — and the attorney's contingency fee comes from the whistleblower's award, not from the government. FCA qui tam relator awards (31 U.S.C. § 3730(d)) range from 15–30% of government recovery, and attorney fees in government-intervened FCA cases are paid by the defendant under § 3730(d)(1). In all of these structures, the attorney's compensation is ultimately contingency-based. But the billing record matters for three reasons: (1) in FCA cases where the government does not intervene, the relator's attorney may need to litigate the case directly and seek attorneys' fees under § 3730(d)(2) under the Hensley lodestar standard; (2) in contested cases, the billing record demonstrates the attorney's investment in the case's development, supporting the contingency fee amount against a client who later disputes it; (3) for portfolio management purposes, the attorney who tracks invested hours per whistleblower matter can calculate the effective hourly rate for each case outcome and make informed intake decisions about which matters to accept.

Q: What is the FCA qui tam seal period, and how long does it typically last?

The False Claims Act requires that qui tam complaints be filed under seal and served on the government (31 U.S.C. § 3730(b)(2)). The seal period begins when the complaint is filed and continues until the government either intervenes, declines to intervene, or the court unseals the complaint on motion. The initial seal period is 60 days, but the government routinely requests extensions while it investigates. In practice, FCA seal periods last 2–7 years — with a median of approximately 3 years according to DOJ FCA statistics. During the entire seal period, the relator's attorney typically maintains quarterly contact with the assigned AUSA or Civil Division attorney, responds to government requests for additional information or documents from the whistleblower, and monitors any investigative activity. All of this contact and coordination is billable work on a contingency case with no immediate compensation — the billing record that ClaimHour builds is the only documentation of the investment during the seal period.

Q: How does the SEC's independent analysis requirement affect billing record obligations?

SEC Whistleblower Program rules under Rule 21F-4 require that a tip based on information from a public source be accompanied by the whistleblower's 'independent analysis' — the attorney's own analysis that makes a 'substantial contribution' to the SEC's understanding beyond what the public source alone would provide. For tips based on financial statement analysis, regulatory filings, or press reports about potential violations, the independent analysis requirement means the attorney must document the specific analytical work performed: the financial models built, the regulatory-compliance analysis conducted, the comparisons drawn across multiple public documents. This analytical work is billable, occurs across multiple irregular sessions (weekend financial model work, evening SEC filing analysis, early-morning cross-reference research), and is among the most systematically undertracked billing categories in whistleblower practice because it occurs before filing and before any matter number has been assigned.

Whistleblower practice operates on two parallel billing timelines that solo practitioners consistently undercount. The pre-filing investigation phase — which may run 6–18 months before any complaint is filed — generates 40–100 hours of billable work per matter across irregular deep-research sessions: whistleblower interview series, regulatory framework analysis, independent analysis development for SEC/CFTC tips, and document authentication review. The government investigation coordination phase — which runs 1–7 years after the FCA or SEC filing while the case is under seal — generates recurring quarterly and monthly government contacts that are systematically compressed or omitted at month-end billing reconstruction. For a solo attorney handling 5 whistleblower matters investigated per year at $400/hr, the annual billing gap from these two phases is $44,000–$76,000 of invested time that the contingency ledger never captures.

TL;DR

ClaimHour captures pre-filing investigation sessions, government coordination calls during the seal period, and multi-agency contact across SEC, CFTC, DOJ, and IRS tracks — passively, no timer, no audio, no document contents. It builds the invested-hours record that whistleblower contingency portfolio management requires. $29–$59/mo. No PMS required.

The pre-filing investigation phase: 40–100 hours before any docket number

Before a whistleblower attorney files an SEC tip, a CFTC tip, or an FCA qui tam complaint, the attorney must conduct a thorough investigation to assess whether the client's information qualifies as "original information" (SEC/CFTC) or whether the client qualifies as an "original source" with "direct and independent knowledge" of the fraud (FCA, 31 U.S.C. § 3730(e)(4)). This investigation generates substantial billable work that has no case number, no docket, and no court filing to anchor it in memory.

A typical pre-filing investigation cycle includes: initial whistleblower interview (90–180 minutes), document collection and review — the whistleblower's own records, any public-source supporting documents, and any government records available through FOIA (10–30 hours depending on matter complexity), regulatory framework research to understand the specific legal theory (securities fraud, accounting violations, FCPA, Medicare/Medicaid false claims, tax evasion — each requires distinct regulatory analysis, 5–15 hours), independent analysis development for SEC/CFTC tips (SEC Rule 21F-4 requires analysis beyond the public source alone, 5–20 hours for financially complex matters), follow-up whistleblower interviews to fill evidentiary gaps (2–4 sessions of 60–90 minutes each), and draft complaint or tip preparation review (5–15 hours).

Total pre-filing investigation: 40–100 hours per matter. In reconstructed billing at month end, this phase often appears as a handful of round-number entries that capture 40–55% of actual time — the weekend financial model sessions, the evening regulatory research, the follow-up whistleblower calls — because no billing milestone forces a contemporaneous record. At $400/hr on 5 matters investigated per year: 80–300 hours of pre-filing work at 50% capture = 40–150 hours untracked = $16,000–$60,000 of invested time per year that the billing record never reflects.

Government coordination during the seal period: 1–7 years of quarterly contacts

Once an FCA qui tam complaint is filed under seal, the government has 60 days to investigate and decide whether to intervene — but in practice, it almost always requests extensions. The average FCA seal period is approximately 3 years; individual cases routinely remain under seal for 5–7 years while DOJ investigates. During the entire seal period, the relator's attorney is the primary liaison between the whistleblower and the government. This liaison function generates ongoing billable work that the month-end reconstruction consistently undercounts.

A typical seal-period coordination cycle generates: quarterly status calls with the assigned AUSA or Civil Division attorney (20–40 minutes each), government requests for additional documents or information from the whistleblower (2–4 requests per year at 30–90 minutes of response time each), whistleblower preparation calls before government interviews (60–90 minutes per interview, with 1–3 interviews per year in active investigation phases), and monitoring of parallel civil or criminal investigative activity that the attorney learns of through government contacts (20–40 minutes of research and analysis per notification). Total: 4–7 hours/year of government coordination time per matter during the seal period.

For a 5-matter active whistleblower practice with an average seal period of 3 years per matter: 60–105 hours of seal-period coordination across the practice at any given time. In reconstructed billing, these calls appear as a few "government follow-up" entries per year that capture 40–55% of actual time. At $400/hr: $9,600–$16,800/year of seal-period coordination time that the billing record undercounts — time invested on a contingency case that may not pay for 2–5 more years.

Multi-agency coordination: SEC, DOJ, CFTC, IRS, and foreign regulators

Complex whistleblower matters — particularly those involving securities fraud with foreign bribery, tax evasion with securities manipulation, or Medicaid fraud with civil RICO elements — may involve simultaneous investigation by multiple agencies. A single whistleblower matter in the healthcare fraud space might involve the Civil Division FCA team, a U.S. Attorney's Office Criminal Division AUSA, the HHS Office of Inspector General, and a state Medicaid Fraud Control Unit. A securities fraud matter with international dimensions might involve the SEC's Division of Enforcement, a DOJ Criminal Division AUSA (for parallel criminal prosecution), the CFTC if commodities instruments were involved, and a foreign financial regulator under an MLAT information-sharing arrangement.

Each agency track generates its own contact sequence: submission (tip or complaint), acknowledgment, investigative inquiries, document requests, whistleblower interviews, and status updates. For a 3-agency matter over a 4-year seal period: 36–60 agency contacts at 20–40 minutes each = 12–40 hours of multi-agency coordination time per matter. In reconstructed billing, these contacts collapse into occasional "government contact" entries. At $400/hr on 2 multi-agency matters per year: $9,600–$32,000 of agency coordination time that the billing record does not capture.

The practical impact is not just billing accuracy: it is case management. An attorney who does not track which agencies have been contacted, when the last substantive contact occurred, and which agency track is most active cannot manage a 4-year multi-agency investigation without a contemporaneous record. ClaimHour's call-duration capture with counterparty identification builds the contact log that manages the multi-agency timeline, not just the invoice.

How ClaimHour fits whistleblower practice

If you represent whistleblowers in SEC, CFTC, FCA, or IRS matters — and you find that your end-of-month review consistently produces fewer hours than the investigation sessions, the quarterly government calls, and the late-night document analysis you actually remember doing — ClaimHour was built for that gap. The passive capture builds the investment record across multi-year matters without requiring a running timer on contingency work. The evening digest surfaces the calls and document sessions from the day for quick matter attribution. Join the waitlist and we'll email when early access opens.

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