MisuseFinancial ServicesFinancePrivilege AbuseCustomer Data InvolvedEmployee Data InvolvedIdentity (basic)Government IDFinancial accountMediumResolved

CITIZENS FINANCIAL GROUP, INC.

bd_54ab7ac601ff327f · schema v1 · pii pii-v1

Severity

Medium

Discovered

Sep 24, 2019

Filed

Oct 2, 2019

To disclose

8 days

Affected

1state residents only

Linked

4 filings

Confidence

67%

Full breach record for CITIZENS FINANCIAL GROUP, INC. →49 incidents on file

Citizens Financial Group notified NH DOJ of a breach involving one NH resident. A vendor employee engaged in unauthorized activity on customer deposit accounts, causing fraudulent transfers. Discovered Sept 24, 2019. Customer reimbursed; credit monitoring offered.

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Incident timeline

discovery → filing · 8 days

Sep 24, 2019

Discovered

Oct 2, 2019

Filed

vs. sector median

7 wks faster

This filing is one of 4 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (3) · sorted by filing gap

Massachusetts State AGbd_72d0f865fc9a80eb2019-11-07 · +36dVerified
New Hampshire State AGbd_aa2727eec0b009752019-11-07 · +36dCandidate
Massachusetts State AGbd_a3022805762cc1a12019-12-09 · +68dCandidate

Name: CITIZENS FINANCIAL GROUP, INC.
norm: citizens financial
Domain: citizensbank.com

Name: CITIZENS FINANCIAL GROUP, INC.
norm: citizens financial
Domain: citizensbank.com
Industry: Financial Servicesllm

Discovered: Sep 24, 2019
Materiality determined: —
Notification sent: Oct 2, 2019
Affected individuals: 1state-resident count only
Data types: Identity (basic)Government IDFinancial account
Attack vector: Insider
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: PartnerFinancial
Regulator citations: Notified its four federal banking regulators
Initial access: insider_action

During the incident: Customer has been reimbursed
Customer notification letter was mailed
All impacted customers were offered complimentary credit monitoring
Notified its four federal banking regulators
Changes made: Partnered with TransUnion Interactive to provide credit monitoring service for two years
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 8 days(8 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 4 filings · 2 states

View merged incident ↗

New Hampshire State AGOct 2 · first · this page

Massachusetts State AG+36d

New Hampshire State AG+36d

Massachusetts State AG+68d

Pattern: first filing Oct 2 (NH), last Dec 9 (MA) — a 68-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://mm.nh.gov/files/uploads/doj/remote-docs/citizens-financial-20191002.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Oct 2, 2019
Raw hash: 307dfa8f77af07297fc1f11e01896375bf72bd02638f5c81b46e5b76ea28eac9

Linked disclosures

Regulatory filings (3) · sorted by filing gap

Reporting entityCITIZENS FINANCIAL GROUP, INC.

Victim entityCITIZENS FINANCIAL GROUP, INC.

Incidentdiscovered Sep 24, 2019

Stated responseCustomer has been reimbursed

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov