The variance between a 42-day BIS filing and a 90-day one is not the regulator. It is what you did in the first six days of the mandate.
The industry average for a BIS/CRS filing sits somewhere around 90 days with a 60% probability of at least one re-submission. The best-run mandates close in 42–50 days with zero re-submissions. The delta between those two outcomes is almost entirely established in the first six working days.
What the first six days should look like
- A complete BOM, mapped line-by-line to the applicable IS standard.
- Third-party test reports assembled and cross-checked before submission — never after.
- A named case owner on both sides (client and advisor) — not a shared inbox.
- Three pre-identified likely audit observations, with responses drafted before the auditor arrives.
The single most important discipline is preparing the technical file to a standard that anticipates the auditor rather than reacts to them. Every hour spent doing this in week one saves roughly six hours in week five.
What buyers routinely underestimate
Regulator engagement is not adversarial. Auditors are looking for defensible files, not for reasons to reject. A well-prepared file rarely faces the difficulties that a rushed file invites. Clients who have only experienced the rushed-file version tend to assume the regulator is the problem — it is not.
