Fixing an Examiner Finding on a Deadline: Where Contract Engineers Help and Where They Hurt

Last updated: November 5, 2026

By Kris Drouet, Engineering Executive, in partnership with KORE1

The first conversation after a finding is really a headcount conversation, even though everyone in the room calls it scoping or workstreams or ownership, because what they’re actually asking is who has the hours to do this. The letter is sitting on the table with a concern, a cause, a consequence and a date on it, engineering already owes the business a quarter of roadmap, and somebody wants the same dozen people to rebuild an access review, produce evidence an examiner will accept and clear a backlog that hasn’t been touched since the last audit. Contractors are the obvious answer. They’re also where I’ve watched good teams make a mess.

I’ve spent most of my career inside lending and mortgage technology, so I’ve been on the receiving end of findings more often than I’d like, and I’ve also been the person who had to decide which pieces of the fix to hand to people who’d be gone by next quarter. A few of those calls were wrong, and the wrong ones looked remarkably alike, which is what this post is about.

Since you’re going to wonder, I write in partnership with KORE1, which places contract engineers, so I obviously have a view on whether you should hire them. My view is that you should, for most of the building and never for the part where someone has to answer for it, and the regulated industry software engineers KORE1 places are built for the building half. Nobody can be hired for the other half.

What Is an MRA, and What Does the Examiner Expect?

A matter requiring attention, or MRA, is a written finding from the OCC or FDIC that a bank’s practice is contrary to prudent operation and could materially harm its financial condition or put the Deposit Insurance Fund at risk, or that it violates banking law. The bank’s board and management must correct it on a committed timeline.

That definition is newer than most people’s mental model. On August 27, 2026, the two agencies finalized a rule (12 CFR 4.92 for the OCC, 12 CFR 305.1 for the FDIC) that allows an MRA only for those two situations, and the OCC says examiners must now share with the bank the basis for issuing one. The FDIC also stopped using its older Matters Requiring Board Attention and Supervisory Recommendations. In FIL-53-2026, it says outstanding ones will be redesignated as MRAs or closed out. If your finding is older than this fall, ask which happened to yours.

What the examiner expects lives in the OCC’s own procedures manual for MRAs. Every MRA is written in five parts, which the OCC calls the Five Cs. The concern. The cause. The consequence of doing nothing. The corrective action the examiner expects. And management’s commitment, with time frames and the people responsible.

Two details in that manual drive everything below. The commitment names individuals. And an MRA closes when the examiner validates that the corrective action was implemented and is effective, not when your engineers say they are done.

One caveat on scope. If you are a nonbank lender, or a fintech riding a sponsor bank, you will not receive an OCC or FDIC MRA yourself. Your version arrives from a state regulator, an auditor, or the bank that sponsors you, usually with a date attached. The mechanics differ. The split between who builds and who answers does not.

What Breaks If the Remediation Date Slips?

Nothing happens on the due date. That is what makes it dangerous. What happens is a status change in a system you will never see, and a conversation that gets harder every time it repeats.

In the OCC’s manual, an MRA the bank has not corrected within the required time frame is Past Due. So is one where the examiner validates the work and decides it did not fix the concern. Late and ineffective get the same label. Meanwhile the manual says that when a bank fails to correct concerns communicated through MRAs in a timely manner, escalation to an enforcement action may be appropriate, and enforcement actions are the category where consent orders live.

Examiners also track history. An MRA is flagged as a repeat when the OCC conveyed the same or a substantially similar concern in the previous three years. Close this one badly and the next letter carries a word you will not enjoy reading.

You can ask for more time. The OCC’s manual lets a bank request an extension in writing, in advance of any relevant due date, and requires the examiner to document the rationale for any extension granted. In advance. The Friday after the date passes is too late. Examiners are also expected to assess progress at least quarterly, so a remediation that looks fine in week two and empty by week ten gets noticed.

Where do dates actually slip? In my experience, in the first two weeks, when the contractors you brought in cannot log into anything. Scoping runs long, access requests sit in a queue, and the clock does not care.

Devin Hornick, a partner at KORE1, has told the team to point its energy at the work “where companies are still investing and where they simply can’t afford to have projects fail or go unfinished.” Cyber and compliance remediation sits squarely in that second half. A finding with a regulator’s date on it is a project that is not allowed to fail.

Where Do Contract Engineers Help?

Everywhere the work is building, and nowhere the work is answering. Here is the split I use, with the KORE1 rate cell that prices each seat.

Source: KORE1 Contract Rate Index 2026-Q4, effective October 16, 2026. The security all-levels cell is KORE1 observed placements, primarily Southern California (7 placements), and the software engineer cell is KORE1 observed placements, primarily Southern California (16 placements). The mid-level and senior security cells are modeled for the United States as a whole.

Which Work Must Stay With the Owners the Examiner Will Talk To?

The rule of thumb is anything with a name on it, because the OCC’s manual says management’s commitment must identify the individuals responsible for implementation and that examiners include the names of those responsible for the concern whenever possible. Those are people who’ll still be on payroll when an examiner follows up a quarter later to ask how the control is holding up, and a contractor on a thirteen-week engagement is long gone by then, so whoever’s name sits in the commitment has to understand the work well enough to defend it to someone whose job is to doubt it.

Contractors hurt in four ways I keep running into. The roll-off comes first, where a contract engineer gets named as owner because they built the thing and nobody else has the time, week thirteen arrives, and the commitment points at an empty chair. Then there’s the access week, which sounds trivial and isn’t, since provisioning in a regulated environment means background checks, identity approvals and a security review of the contractor, none of which starts until the contract does, so I plan on the first week producing very little and sometimes the second.

The third is worse because it looks like success. A contractor builds a clean evidence pipeline, writes a thin README and leaves, and six months later an examiner asks how it works under the hood and your team shrugs. The OCC’s procedures have examiners close an MRA once the corrective action is validated, without waiting to see it sustained, and they’ll hold the bank accountable if the practice reoccurs in a way that meets the MRA standard, so the fix can pass and you can still be back in the same room a year later. The fourth is a contractor who builds a control and then attests to it, and I separate those every time, because the person who built it doesn’t get to say it works.

It’s the old myth in a new coat, the one that says engineering leaders eventually stop being technical. Whoever answers for the control will get a technical question, and if that person can’t answer it, the contractor sitting behind them can’t answer on their behalf, so hire contractors to build and make sure an employee can explain every line of what they built.

How Do You Run the Remediation?

The most common thing I see when a remediation goes sideways is not a technology problem. It is a clarity problem. I call the diagnosis the Clarity Stack, and it has three layers that stall nearly every one of these efforts. Leadership does not know what done means. Priorities are not written down where the whole team can see them. Decisions are made in hallways instead of systems.

For a finding, the first layer has a precise answer, and it is free. Done means examiner-accepted evidence. Not a merged pull request. Not a green dashboard. Evidence that the corrective action was implemented, evidence that it works, and a form the examiner can validate without a guided tour. My standing reply to “it’s done” is show me the data.

Run it like this.

• Copy the corrective action language from the finding into a tracker, word for word, and attach one employee owner and one date to each line. Contractors get tasks under those lines, never the lines themselves.
• Write down what accepted evidence looks like for each line before anyone builds anything, and ask the examiner or your sponsor bank whether it would satisfy them. One message now beats a rebuild later.
• Decisions go in the tracker, not the hallway. If the scope of a control changes, that is a dated entry with a name, because your auditors will ask when and why.
• Ask internal audit to validate the work before the examiner arrives. The OCC’s manual tells examiners to substantially rely on validation work done by internal audit when that function is rated satisfactory, which can shorten the examiner’s own review considerably.
• Put the milestone dates ahead of the quarterly follow-up. Think week four, week eight, week eleven.

Everything in that list is operating discipline, and none of it is glamorous. It is also what pipeline-generated audit evidence looks like when it is working, and the staffing of a first audit cycle is covered in how a SOC 2 cycle changes an engineering team’s week. If you want the broader picture of engineering leadership under regulation, I wrote that up in where regulated-industry engineering actually differs.

What Does a Remediation Sprint Cost?

Contractors bill hourly, so the figure moves with the weeks you use. Here are the four cells at 40 hours a week for 13 weeks.

Source: KORE1 Contract Rate Index 2026-Q4, effective October 16, 2026. A bill rate covers wages, payroll taxes, insurance, and KORE1’s recruiting and account management. The methodology page explains observed versus modeled cells. The modeled cells start from the BLS Occupational Employment and Wages release for May 2025 and add a 24 percent burden.

Fine print, because I would rather say it than have you find it. The $82 security median rests on seven placements and the range runs from $70 to $124, which is wide, so treat it as “security engineers KORE1 has placed in Southern California bill about this” and not as a floor. Note too that the quiet cost is the first week, when a seat is billing while it waits for access. If the work is mostly security findings from a pentest or audit, cybersecurity remediation staffing scopes that as a sprint with a finish line.

Questions Engineering Leaders Ask After the Finding Lands

Can contract engineers help us remediate an MRA before the deadline?

Most of the build work, yes. Contract engineers can automate evidence, build controls, and burn down the backlog, while your employees keep the commitment, the root-cause conclusion, and the examiner conversation. Start the seats in week one, because access and scoping eat the first stretch.

Who can’t be a contractor on this?

Whoever the commitment names. The OCC’s procedures require management’s commitment to identify the individuals responsible for implementation, so those people have to outlast the sprint. I would add the person who signs closure and whoever sits across from the examiner.

Is an audit finding the same as an MRA?

No. An MRA comes from a bank examiner under a defined standard, while an audit finding comes from an auditor, such as a SOC 2 exception, and carries only the timeline someone imposes on it. The remediation discipline is the same either way. You still need a named owner, a written definition of done, and evidence a reviewer can check without help from you.

Can we get more time if we are going to miss the date?

Sometimes, if you ask early. In the OCC’s procedures the bank requests an extension in writing, in advance of the relevant due date, and the examiner must document the rationale for any extension granted. Asking after the date has passed is a much harder conversation.

What does a remediation sprint cost?

$97,500 to $173,300 for a 13-week sprint of two or three seats at KORE1 medians (KORE1 Contract Rate Index 2026-Q4). Contractors bill hourly, so an eight-week sprint costs less than the 13-week figure, and the first week often bills while seats wait for access.

Build It With Contractors. Answer For It Yourself.

Every remediation I have been part of that went badly had the same root. Somebody handed the answering to somebody who was not going to be there. Every one that went well kept the building flexible and the accountability fixed, and wrote down what done meant before the first line of code.

If you have a finding and a date, and your engineers are already at capacity, talk to the KORE1 team about which seats to fill first. And if you want a second set of eyes on how to split the work, connect with me on LinkedIn. I read the DMs.

Data as of November 2026. The KORE1 Contract Rate Index refreshes quarterly, and this page is refreshed with it. The OCC and FDIC figures and rule language reflect their August 27, 2026 issuances.