Frequently Asked Questions for Outside Counsel on the FDIC's Advanced Legal Information System (ALIS)
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- Q— Our firm is already subscribed with the FDIC's electronic billing contractor, Wolters Kluwer. Does our firm need to provide the FDIC with Timekeeper IDs?
- Q— Our firm does not have any active cases at this time but has done work for the FDIC in the past. . We are not currently subscribed with Wolters Kluwer, the FDIC's electronic billing contractor. Do you need the Timekeeper IDs now, or should we wait until we receive a referral?
- Q— Our firm has hired new lawyers, so when the FDIC asked for us to supply Timekeeper IDs for all of our billing professionals, I included the new hires on that form and e-mailed it to the FDIC. Is that okay?
- Q— When we submitted the Timekeeper IDs on the forms identified in your February 1st letter, our firm performed a few minor adjustments to the hourly rates of our attorneys who have made partner. Can we expect those slight increases to go through your system?
- Q— We are a small firm and have been outside counsel for the FDIC on only a few matters. Our firm has always submitted monthly, paper invoices. Is it mandatory that we subscribe with Wolters Kluwer and use electronic billing under the FDIC's new ALIS system?
- Q— Many law firms use the American Bar Association's Uniform Task-Based Management System (UTBMS) codes when assembling their monthly fee and expense invoices. Will the FDIC incorporate or mandate the use of UTBMS billing codes under ALIS?
- Q— Our firm has several professionals whose hourly rates, due to the calculations for FDIC discounts are not in whole dollar amounts. For example, attorney Black bills at $255.50 per hour. Is this okay?
A— Firms already subscribed for electronic billing with Wolters Kluwer do not need to send the FDIC any Timekeeper IDs, because we already have them, unless you are adding a new provider, updating a provider’s name or rate, or removing a provider. Only firms submitting paper invoices or those not registered for E-billing with Wolters Kluwer need to supply the FDIC with Timekeeper IDs and should do so at once if they have not yet replied. The web link and contact information are provided below in the answer to Question 2.
A— Please send them in now. Under ALIS (the new FDIC system, the Advanced Legal Information System), the Legal Division requires Timekeeper IDs from all firms that have a Legal Services Agreement, including those that use monthly paper invoice submissions and those that may later upgrade to electronic billing.
Currently, most forms must be mailed in to the Legal Division with original signatures. To easier collect the Timekeeper IDs from firms that have a current Legal Services Agreement, we are making a limited exception and accepting the updated Rate Schedule forms through our mailbox, ALIS@fdic.gov. The web link for the correct, updated Rate Schedule Form is: https://www.fdic.gov/formsdocuments/f5210-10.pdf (do not use this form to add new billing professionals or to change any current hourly billing rates; see Questions 3 and 4). The form should be printed, completed and returned to us attached to your email response.
A— In this case you have used the incorrect form. The only acceptable way to add or subtract billing professionals is by completing the Amendment form. If you added or subtracted billing professionals in your e-mail submission of the Timekeeper IDs, you will need to resubmit those new or subtracted billing professionals on the correct Amendment form. Attorneys not approved by the Legal Division under your Legal Services Agreement may not bill for professional services until the Amendment is approved in writing by the authorized representative of the Legal Division.
Amendment forms to add or subtract billing professionals must be mailed in and, at this time, cannot be electronically filed. The correct mailing address to file an Amendment of your Legal Services Agreement is:
FDIC Legal - Outside Counsel Mgmt. Grp.
3501 Fairfax Drive (VS-E-6097)
Fairfax, VA 22226
A— No, you will need to resubmit those forms using the hourly rates already agreed to in your firm's current, 2-year Legal Services Agreement with the FDIC. Hourly rates of billing professionals are not subject to adjustment during the 2-year term of your Legal Services Agreement. Any proposed increases in the hourly rates of billing professionals at the time of your renewal must be accepted in writing by senior management of the Legal Division before they become effective.
A— The FDIC encourages the use of electronic billing, but it only becomes mandatory once your firm bills $100,000 in fees and expenses during your two-year Legal Services Agreement. Please note, however, that Electronic billing presents several advantages over the submission of paper invoices, and we recommend that you consider upgrading. For example, your firm will be able to instantly and securely submit agreed upon case budgets, as well as monthly invoices for your firm's fees and expenses. Invoices will also be easier to locate and track in our electronic system. You may contact Wolters Kluwer, our electronic billing service provider at www.wolterskluwer.com.
A— The Legal Division will not mandate the submission of UTBMS billing codes under ALIS. Firms that automatically submit invoices using UTBMS may include the codes with their individual billing entries as long as they are accompanied by an explanatory narrative of the time entry. For additional information on necessary billing detail, see the FDIC Outside Counsel Deskbook, Chapter 8.
A— No, all time-billers in each outside counsel law firm must have an hourly rate in whole dollars only. Therefore the Rate Schedules or Amendments that each firm completes must contain no decimal/cents in the approved hourly billing rate.