📄 Migrate 17Ad-7(f)(5)(ii) Backup Custodian with new forum#19
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Co-authored-by: Codex <noreply@openai.com>
This was referenced May 21, 2026
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Really, we're going to need to expand this and make new arrangements with monitoring clauses under Reg S-P to account for a total loss scenario of the TA-1 address, such as a bombing. We should be able to recover from that scenario without unreasonable loss (maybe a few weeks of updates if we batch-process updates and communicate with the custodian through a recovering mTLS). |
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We need to migrate the Backup Custodian arrangement from August 31, 2021 into the current organizational records structure. It ties a lot into the S-P retention, and there are some material places we can upgrade our arrangements in accordance with the decentralizing efforts onto GitHub.
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Moves the existing August 31, 2021 Backup Custodian arrangement into the current records framework.
This PR is primarily a records migration and organization step. The goal is to preserve the existing Backup Custodian arrangement while preparing the compliance records structure for the next stage of retention, vendor oversight, and Regulation S-P-related incident response documentation.