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Extract to table / workstream-3-cdd-edd-remediation-plan.docx
workstream-3-cdd-edd-remediation-plan.docx
Parties
Harkness LLP
For Inc
Thornfield Consulting Group LLC
Drayton Mercer LLP
Pope LLP
NovaPay Technologies Inc
FairLend Digital LLC
VaultEdge Inc
Dates
May 15, 2025
January 15, 2025
July 15, 2025
January 15, 2026
February 28, 2025
February 15, 2026
February 10, 2025
April 1, 2025
September 15, 2025
December 15, 2025
Amounts
$4,300,000
$42,500,000
$74.3
$30.5
$1.4
$127.4
$10,000
$300,000
$3,600,000
$150,000
Obligations
The BaaS business line thus represents a material revenue contributor to the Bank, which must be balanced against the compliance risks that the channel presents
Any risk of missing the July 15, 2025 (50% remediation) or January 15, 2026 (100% remediation) milestones must be escalated immediately by the Workstream Lead (Ikeda) to the Workstream Sponsor (Langston) and the C&H responsible partner (Hartmann)
This means that approximately 8,500 Tier 2 accounts must be remediated between June 1 and July 15, 2025, following the completion of Tier 1
Critically, the prioritization methodology must be independently validated by Thornfield Consulting Group before full-scale remediation commences