The officer who sits the exam. Dodd-Frank, Basel, BSA/AML, and a CCO line that is either real or it is not. Not a general counsel search with a bank logo pasted on.
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Lorenzo Sartori — Founder, Sartori & Partners·— Bank general counsel search: the officer who sits the exam, on a 24-day shortlist and an 11-week median offer.
A bank general counsel search hires the officer who sits the exam, briefs the board on Dodd-Frank and the March 2026 Basel capital proposals, and leaves BSA/AML with the CCO. Of 38 General Counsel and Chief Legal Officer placements since 2017, the shortlist arrived in 24 days and the median accepted offer in 11 weeks (range 8-16). A Series C fintech in San Francisco put interim general counsel live on day 6, separate from those 38. Median total pay for 23 full-year financials general counsel named in the 2026 proxy season was $6.66 million.
01Direct answer
A bank general counsel is the officer who owns the supervisor relationship, not a scaled commercial GC.
Financial services legal recruiters who cannot name the charter will send the wrong shortlist. We scope the supervisor before we map names.
A bank general counsel search is the retained hire of the general counsel or chief legal officer at a depository institution, a bank holding company, a broker-dealer, or a payments firm. The work is examiner relations, the Dodd-Frank and capital brief to the board, the privilege line with a chief compliance officer, and the decision about which matters stay inside. It is a different product from general counsel search for a company whose legal risk is contracts, privacy, and a board that does not take a call from the OCC.
Sartori & Partners has completed 230+ in-house and corporate placements since 2017, of which 38 were General Counsel or Chief Legal Officer. There is no separate published count of bank general counsel searches. Those mandates run on that GC clock: shortlist in 24 days, median accepted offer in 11 weeks, range 8-16, measured on the 38 from 2017 through 2026. Offer acceptance on corporate mandates is 96 percent. Retention of placed in-house leaders is 97 percent at 12 months and 91 percent at 24 months. The replacement term on a retained GC search is 12 months.
The market the hire walks into is countable. The FDIC reported 4,278 insured institutions as of March 31, 2026, of which 3,763 were commercial banks and 515 were savings institutions, and 54 were problem institutions. FINRA's 2026 Industry Snapshot counted 3,184 member broker-dealers at year-end 2025. Those are institutions, not open GC seats. Most will not hire this year. The ones that do are hiring against an exam calendar, not against a job board.
Seat
General counsel or CLO for a bank, broker-dealer, or payments firm. Examiner relations first.
Clock
Shortlist in 24 days; median accepted offer in 11 weeks; range 8-16 weeks (n=38 GC/CLO, 2017-2026). No separate bank-only tally.
Proof
38 GC/CLO of 230+ in-house placements since 2017; 96% offer acceptance; 97% still in post at 12 months.
Terms
Retained only. Fee 25-30% of total first-year compensation, 30% of the fee as retainer, 12-month replacement.
When not
A first GC at an unregulated company, or a standalone CCO search. Those are sibling mandates.
Pay context
Financials NEO median total $6.66 million, median salary $730,000, 23 full-year rows, 2026 proxy season. Not a community-bank bid.
02Why a separate brief
Three institutions. Three supervisors. One copied GC specification fails all three.
The parent mandate stays the cross-industry general counsel search. The industry cut is the charter and the exam.
Dodd-Frank, Basel, BSA/AML, and the exam. Four files. One officer has to know which file is theirs.
Dodd-Frank section 165 is still the enhanced-prudential frame. The Economic Growth, Regulatory Relief, and Consumer Protection Act in 2018 raised the general asset threshold for those standards from $50 billion to $250 billion. A GC at a holding company above that line owns the board conversation on capital, liquidity, stress testing, and resolution planning. A GC at a bank well below it still owns the exam, the Bank Holding Company Act questions on a deal, and the consumer file. The threshold tells you which statute is live. It does not tell you the person can sit the exit meeting.
Basel is a 2026 briefing problem, not a 2010 vocabulary test. On March 19, 2026 the Federal Reserve, the FDIC, and the OCC requested comment on three proposals to revise the US capital framework, including implementation of the remaining Basel III components for the largest, most internationally active banks, and a move from two risk-based calculations to one. Comments were due June 18, 2026. The candidate we put in front of a board can explain what that package would change in the bank's own numbers. Reciting the 2023 draft is not the same skill.
BSA/AML is the file that ends careers when it is staffed as a policy. On October 10, 2024 FinCEN assessed a record $1.3 billion penalty against TD Bank for Bank Secrecy Act failures, with a four-year monitorship, and called it the largest penalty against a depository institution in FinCEN's history. The same day the Department of Justice announced a guilty plea in a $1.8 billion resolution for BSA and money-laundering conspiracy violations. The GC does not personally file the SARs. The GC does own the question of whether the program was resourced, whether the BSA officer could escalate, and whether the board heard it before the agency did.
Examiner relations are the daily job. Matters requiring attention, matters requiring immediate attention, and the response letter are the work product. A dossier that says "regulatory experience" and cannot name an examination, a finding, and what the candidate did in the next quarter is not a shortlist entry. FDIC data put problem institutions at 54 as of March 31, 2026, out of 4,278 insured institutions. The relevant experience is the exit meeting, not proximity to one.
What the 2026 bank GC brief has to name. Status is the public rule, not a Sartori reading of a client's exam.
File
What it asks of the GC
Status we brief against
Dodd-Frank section 165, after the 2018 threshold change
Enhanced prudential standards generally from $250 billion in assets, up from $50 billion. Capital, liquidity, stress tests, resolution.
Statute. The 2018 Act raised the general threshold.
US capital proposals, March 19, 2026
Largest internationally active banks: remaining Basel III components, one risk-based calculation rather than two. Other banks may opt in.
Proposed by the Fed, FDIC, and OCC. Comments were due June 18, 2026.
BSA program, 31 CFR 1020.210
The board designates a BSA compliance officer. The GC knows whether that officer can escalate, and whether the program matches the products.
In force. FinCEN's record depository penalty was $1.3 billion on October 10, 2024.
OCC Heightened Standards, 12 CFR Part 30, Appendix D
Independent compliance-risk management, separate from the front line, at or above $50 billion in average total consolidated assets.
In force at $50 billion. A December 30, 2025 proposal would move the threshold to $700 billion.
Do not collapse these into one 'regulatory GC' line on the specification. The scorecard names which file this hire owns and which file a CCO or BSA officer owns.
Source: Federal Register (Nov. 29, 2018; Dec. 30, 2025); Federal Reserve, FDIC, and OCC joint release, March 19, 2026; eCFR; FinCEN news release, Oct. 10, 2024.
04GC and CCO
The overlap is a reporting-line decision. It is made in week 1 or it is made by the supervisor.
One officer
At a smaller bank the general counsel is often the chief compliance officer and the BSA officer the board has designated. That is a lawful design when the asset size does not trigger an independence rule and the board has said so. The hire is still a general counsel search, with a compliance-heavy scorecard. It is not a first general counsel search copied from a software company, and it is not a CCO search with a law degree added at the end.
Two officers
Appendix D requires a compliance-risk program independent of front-line units for covered banks at or above $50 billion in average assets. A GC who can overrule the CCO on a product launch is the defect the guideline is written against. The CCO mandate is chief compliance officer search. The BSA, MLRO, or sanctions desk is sanctions and AML recruitment. We will not merge them to save a fee.
05Who we map
The pool is people who have owned an exam, not people whose CV says financial services.
Law-firm partners, former examiners, and sitting deputies fail in different ways. The scorecard says which failure the client cannot afford.
A
Sitting GC or deputy at a similar charter
The default. They have written the response to a finding, managed outside counsel against an agency, and sat with a board that has already lived an exam cycle. A deputy who has only run contracts inside a bank is not this person. National-bank experience does not automatically transfer to a state nonmember, or the reverse.
B
Former examiner or agency lawyer
Useful when they have also run a department, a budget, and a board pack. The failure mode is hiring the person who issued findings and has never owned remediation, privilege, or a CEO who wants the product to ship. Agency pedigree is a screen, not a qualification.
C
Law-firm bank regulatory partner
Often the right outside counsel and the wrong general counsel. They have seen many exams and owned none of the aftermath inside the building. We will map them when the seat is a large legal department that already has deputies for the daily file. We will say so before outreach, not after the third interview.
D
Broker-dealer or payments GC, moved across
A FINRA-facing GC and a money-transmitter GC are real officers. They are not a substitute for a depository GC unless the client's supervisors match. Dual registrants and sponsor-bank payments firms are the cases where the pools touch. We name the touch in the blueprint. We do not assume it.
Across industries, not as a bank-only finding, 84 percent of chief legal officers report to the chief executive in the ACC 2026 Chief Legal Officers Survey. A bank GC who reports only through the CFO will not survive the first examination that asks who owns the legal view. Reporting line is a week-1 term.
06Mandate scorecard
Five lines we lock in week 1. Outreach does not start without them.
01
Charter and supervisors. OCC, Federal Reserve, FDIC, state banking department, SEC, FINRA, CFPB, FinCEN. The list is the client's, written down. A search that says "bank regulatory" and does not name the agency is not ready.
02
One officer or two. GC alone, GC plus CCO, GC plus a designated BSA officer. Matched to asset size and to Appendix D. If the board wants one person, the letter says so. If the rule wants two, we open two searches.
03
Cash, equity, and what the proxy median is not. For a large listed financial the 2026 salary median among disclosed GCs is $730,000, inside the cross-industry large-cap base band of $650,000 to $1.1 million. The $6.66 million figure is total compensation for named executive officers, grant-date value included. We do not open a search on a number the compensation committee will not pass, and we do not quote the median total as a community-bank salary.
04
The work that cannot wait 11 weeks. A live exam, a consent-order article, a capital proposal the board must discuss, a sponsor-bank exit. That work is interim legal talent in parallel. Median start is 7 days across 60+ interim and fractional engagements. US interim GC day rates run $1,800 to $3,200. Days billed credit against a later retained fee.
05
Off-limits and conflicts. We never recruit from a client's legal department for 24 months after a mandate. We never approach lawyers we placed for as long as they stay. Both go in the letter with the fee, before the first call.
07How the search runs
The GC clock is 24 days to shortlist. The median accepted offer is week 11.
Week 1Mandate Blueprint
Charter, supervisors, GC versus CCO, cash and equity, live exam risk, off-limits. Written. No calls before this exists.
Weeks 1-2Total-market mapping
Sitting GCs and deputies at institutions with the same supervisor. Broker-dealer and payments pools are mapped only if the blueprint says they count.
Weeks 2-4Private outreach
Blind both ways until mutual interest. No CV leaves us without written candidate consent. NDA on request.
Day 24Shortlist dossiers
Each name has sat an examination the client will recognize. Assessment dossiers, not a stack of financial-services resumes.
Weeks 5-11Interviews and offer
CEO, chair, often the audit-committee chair. Median accepted offer at week 11, range 8-16, on 38 GC and CLO searches since 2017.
After startClose and 90-day checks
Onboarding and 90-day check-ins. 97 percent of placed in-house leaders still in post at 12 months; 91 percent at 24 months.
Process detail is on how we run a search.
If the company has never had a GC at all, the sequencing note is
first general counsel search,
read against this regulatory scorecard rather than instead of it.
08What to budget
Proxy totals for disclosed financials GCs. Not a salary, and not a fee quote.
The 2026 proxy season is the public record. It covers general counsel who are named executive officers. It does not cover the GC a $4 billion bank did not have to disclose.
General counsel pay, financials companies inside the 500 largest US-listed companies by public float. Full-year sitting GCs who are named executive officers. 2026 proxy season.
Measure
Financials
All sectors, for scale
What it is not
Full-year rows in the statistic
23
236
Not the count of banks that employ a GC
Companies in the 500 / with a GC among named executives
74 in the universe; 25 with a GC named executive
236 full-year GCs of 490 companies with a readable compensation table
Most bank GCs are not in this table
Median salary
$730,000
$660,473
Not total pay
Median total compensation
$6.66 million
$4.76 million
Grant-date value. Not a base. Not a fee base
Total, 25th to 75th percentile
$4.37 million to $13.44 million
$3.19 million to $7.21 million
Inclusive of equity awards as reported
Median equity share of total
57.8%
60.5%
Stock and options at grant-date fair value
Median GC total as a share of CEO total
24% (21 companies)
25.5% (229 companies)
CEOs with table pay under $1 million are excluded
Fee is 25-30 percent of the hire's total first-year compensation, with a retainer of 30 percent of the fee at engagement. Do not apply that percentage to the $6.66 million median. The cross-industry large-cap base band is $650,000 to $1.1 million; the financials salary median of $730,000 sits inside it.
Source: Sartori & Partners analysis of SEC proxy filings, 2026 proxy season (proxies filed October 2, 2025 to September 25, 2026). General Counsel Pay dataset.
The audit committee wanted a CCO who had sat across a supervisor. Compliance could not report as a sub-function the GC could overrule.
Approach
Assessed against the DOJ Evaluation of Corporate Compliance Programs. Dossiers named examinations. Reporting line to the audit committee, working line to the GC.
Outcome
Shortlist in week 3. Accepted offer in week 10. One of 41 compliance-leadership placements since 2017.
We thought we needed a full-time GC. They said fractional for two quarters, then a permanent search. Both were right. The fractional counsel started in a week.
Chief ExecutiveSeries C payments company · San Francisco
Fee, replacement window and off-limits were in the letter before they called anyone. That is the only way I will sign a search firm. The hire accepted on the first offer.
CFOLondon-headquartered private-credit manager · London
A retained search for the general counsel or chief legal officer of a bank, a broker-dealer, or a payments firm. The seat owns examiner relations, the board pack on Dodd-Frank and capital, and the line between legal and the BSA/AML program. It is not a general counsel search with a bank named in the title. The industry map is financial services and banking.
How is this different from a general counsel search?
The cross-industry general counsel search hires a commercial and board lawyer. First GC, succession, and deputy sit on in-house counsel recruiting. A bank general counsel search adds the charter, the supervisor, and the question of whether compliance is a separate officer. Copying a technology GC specification fails here: the first test is an exam the candidate has sat, not a financing they have closed. Method for any GC seat: how to run a general counsel search.
Should the general counsel also be the chief compliance officer?
Only if the charter and the asset size allow it, and only if the board says so in week 1. Under 31 CFR 1020.210 the board designates a BSA compliance officer. OCC Heightened Standards, 12 CFR Part 30 Appendix D, require an independent compliance-risk program at banks with average total consolidated assets of $50 billion or more; a December 30, 2025 proposal would raise that threshold to $700 billion and is not a final rule. Where independence is required, the CCO search is a separate mandate, and the BSA officer is a sanctions and AML search.
How long does a bank general counsel search take?
On the 38 General Counsel and Chief Legal Officer placements since 2017, the shortlist arrived in 24 days and the median accepted offer in 11 weeks. The range is 8-16 weeks. There is no separate published bank-only clock. If an exam, a consent order, or a financing sits inside that window, interim cover runs in parallel: median start is 7 days across 60+ interim and fractional engagements, counted outside the 38. A Series C fintech in San Francisco was live on day 6. See how we run a search.
What should we budget for a bank general counsel?
For sitting general counsel who are named executive officers at financials companies in the 500 largest US-listed companies, the 2026 proxy season shows a median total of $6.66 million and a median salary of $730,000, on 23 full-year rows (Sartori & Partners analysis of SEC proxy filings). That total is not a community-bank bid and not the fee base. The cross-industry large-cap base band is $650,000 to $1.1 million. The retained fee is 25-30 percent of the hire's total first-year compensation, with 30 percent of the fee paid as a retainer at engagement. Full proxy set: General Counsel Pay.
Who is actually in the candidate pool?
Sitting general counsel and deputy general counsel who have owned an exam at a similar charter: OCC national bank, Federal Reserve member, FDIC state nonmember, or a state supervisor. Former examiners who have also run a department. Broker-dealer counsel who have owned FINRA Rule 3310 are a different pool from depository counsel, as are payments lawyers who hold money-transmitter licenses. We do not start from a rented list of financial services legal recruiters' advertised CVs. Sub-sectors: commercial and retail banking, broker-dealers, payments.
Do you work these searches on retained terms only?
Yes. Every search is retained. The fee is 25-30 percent of total first-year compensation. A retainer of 30 percent of the fee is paid at engagement and kept if the search is cancelled. The replacement window on a GC, CLO, or CCO search is 12 months. We do not approach lawyers we placed for as long as they stay, and we do not recruit from a client's legal department for 24 months after a mandate. Fee, replacement, and off-limits are in the letter before anyone is called. Offer acceptance on corporate mandates is 96 percent.
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