You write the surveillance section of the application. A running program is a better exhibit than a narrative — and it is ready in the time it takes to ingest one CSV.
A surveillance program against planted ground truth: 23 detectors with regulatory anchors, thresholds under maker-checker, and a generated Exhibit L. The methodology is public and rendered from the code, so the application text and the system cannot drift apart.
A read-only counsel seat in the client's workspace (scoped and time-boxed like a regulator seat), the recorded walkthrough, the one-pager and 90-day PoV playbook to hand over, and a standing answer to "show me the surveillance" — the same screens an examiner will see.
We don't pay referral fees and we don't ask for exclusivity. We do give your team a walkthrough, keep counsel copied on the PoV report, and turn around questionnaire answers in a day. If your client already has a vendor, say so — we'd rather know.