For banks, processors and other relying parties
How review pricing works
Bank-grade review from $50,000 all-in; most relying parties pay far less net.
List prices
Three tiers, each with a 12-month bring-down covenant
The review is performed for you, the party relying on the opinion. The firm never reviews an opinion for the operator that commissioned it.
Bank-grade review
$50,000 all-in · $20,000 each later review
- Attorney-signed sealed review record
- Second reader
- Federal analysis plus the operator’s state footprint
- Privileged engagement with the relying party
- Examiner pack
- 12-month bring-down covenant
Bank-grade review + 50-state / prediction markets
$65,000 all-in · $26,000 each later review
- Everything in the bank-grade review
- Local-counsel checks in high-risk states
- CFTC and state preemption analysis for prediction markets
Tier-1 co-signed review
from $100,000
- Everything in the 50-state review
- Co-signature by a payments practice at another firm (its fee passed through)
What lowers the net cost
Reductions that reflect the work, not a referral
- Subsequent review or reuse
- A later review of the same operator, or a review of an opinion version already reviewed in the last 12 months, is $20,000 instead of the $50,000 first review. No client is told who the other relying parties are. A true-up credit to earlier clients is subject to ethics review and is not offered yet.
- Volume tiers
- On reviews you pay for: 10% at 10+ merchants, 20% at 40+ merchants, 30% at 150+ merchants.
- Portfolio subscription
- Per merchant per year, by book size: $6,000 at 10+, $4,500 at 40+, $3,000 at 150+. It includes every bring-down, law-change monitoring and the examiner dashboard, so a re-review is never billed per event.
- Operator-funded review
- Your onboarding policy may require the operator to fund your review (ABA Model Rule 1.8(f)). You remain the only client, the fee is fixed and paid before the outcome, and the findings are reported to you alone.
- Verified-Opinion fast track
- The opinion’s statement of facts cites measured Pathways evidence (signed receipts). Such an opinion takes far fewer hours to review, so it is priced at 50% of list.
Never offered: credit for referring another bank or relying party, any share of a legal fee to anyone, or a fee that depends on the outcome of the review.
Illustrative
What a relying party might pay over 12 months
Illustrative only, not a quote. Assumes 50% of reviews are operator-funded, 30% of the rest reuse an already-reviewed opinion, one bring-down per merchant per year, the bank-grade tier, the volume tier and the portfolio subscription. Your mix will differ.
| Merchants on the book | Relying party pays (12 months, illustrative) | Per review or bring-down (illustrative) |
|---|---|---|
| 10 | $244,500 | $12,225 |
| 40 | $836,000 | $10,450 |
| 150 | $2,602,500 | $8,675 |
List prices for an independent review performed for the relying party. A list price is not a quote: each review is scoped and fixed in an engagement letter before work starts, and only that letter binds the firm. Net figures are illustrative, computed from the stated assumptions. Attorney advertising.