Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / ongoing-compliance-obligations-memo.docx
ongoing-compliance-obligations-memo.docx
Parties
HARKNESS LLP
Skybridge Fintech Ltd
Kestrel Risk Advisors LLC
Ketchum LLP
Kestrel Services Inc
OCC Computer-Security Inc
Ironvault Security Group LLC
Federal Deposit Insurance Corp
Dates
February 12, 2026
February 15, 2026
January 1, 2025
December 31, 2025
January 1, 2026
December 31, 2026
October 2, 2026
September 15, 2025
October 1, 2024
October 1, 2025
Amounts
$2.74
$13.7
$10,000,000
$20,000,000
Obligations
Coverage limits must remain at or above $10,000,000 per occurrence and $20,000,000 in the aggregate, consistent with the DPA's requirements
This general authorization is subject to a critical procedural requirement: Skybridge must provide Meridian with at least thirty (30) days' prior written notice before engaging any new sub-processor or replacing an existing sub-processor
Under the FDIC/OCC Computer-Security Incident Notification Rule (12 CFR Part 53, effective April 1, 2022), Meridian is required to notify its primary federal regulator (the OCC) within thirty-six (36) hours of determining that a "notification incident" has occurred — i
Notification under Article 33 must be made within seventy-two (72) hours of becoming aware of the breach
A processor must adhere to the instructions of the controller regarding the processing of personal data
A processor must assist the controller in responding to consumer rights requests, including requests for access, correction, deletion, and data portability