As a processor, Heartland's pain is certainly much more severe than what would be inflicted on a retailer involved in a similarly large breach. But $229 million is starting to look like real money. Think of that $100 million in the bank as sort of mad money, in the sense that it's needed because everyone Heartland has done business with seems to be driven stark raving mad. It's less hush money than "please don't hurt me" money.
In its latest financial report, Heartland Payment Systems reported that it dropped $129 million on data breach costs last year (an incident that briefly placed Heartland on Visa's Bad Breach Boy list). The company added that it still has a reserve of $100 million for additional expenses.