HackingFinancial ServicesFinanceStolen CredentialsCustomer Data InvolvedTargetedIdentity (basic)Government IDFinancial accountMediumContained

CLARFELD FINANCIAL ADVISORS, LLC

bd_5c495154926ba30c · schema v1 · pii pii-v1

Severity

Medium

Discovered

Mar 9, 2018

Filed

Mar 16, 2018

To disclose

7 days

Affected

21state residents only

Linked

3 filings

Confidence

66%

Full breach record for CLARFELD FINANCIAL ADVISORS, LLC →

Clarfeld Financial Advisors notified the NH AG that unauthorized actors accessed the Schwab Advisor Center using compromised credentials on Feb 22-23, 2018. The incident exposed names, SSNs, addresses, and Schwab account numbers for 21 NH residents. Schwab deactivated credentials and Clarfeld engaged forensic investigators, provided 2 years of credit monitoring, and issued notices on March 16, 2018.

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Incident timeline

undetected · 15 days

discovery → filing · 7 days

Feb 22, 2018

Begins

Mar 9, 2018

Discovered

Mar 16, 2018

Filed

vs. sector median

8 wks faster

This filing is one of 3 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Massachusetts State AGbd_d15d683d9edcb2132018-03-16Verified
Montana State AGbd_705d510443dde4682018-03-09 · +7dCandidate

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: CLARFELD FINANCIAL ADVISORS, LLC
norm: clarfeld financial advisors
Industry: Financial Servicesllm

Discovered: Mar 9, 2018
Breach occurred: Feb 22, 2018 – Feb 23, 2018
Undetected for: 15 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 16, 2018
Affected individuals: 21state-resident count only
Data types: Identity (basic)Government IDFinancial account
Data elements: Social Security number
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid AccountsT1114 Email Collection
Threat actor: ExternalFinancial
Regulator citations: Notified Office of the New Hampshire Attorney General
Initial access: valid_credentials

During the incident: Schwab Security Administration Center identified the unauthorized access and deactivated the intruder's compromised credentials
Working with forensic investigators to verify the nature and scope of the incident
Providing all potentially affected individuals access to 2 free years of credit and identity monitoring services through All Clear ID
Established a dedicated hotline for potentially affected individuals
Providing potentially impacted individuals with guidance on how to better protect against identity theft and fraud
Providing written notice of this incident to other state regulators as necessary
Changes made: Conducting a review of our systems and processes, assisted by outside cybersecurity experts, to learn the cause of this intrusion
Schwab is offering our clients access to a client 'token' for an additional layer of security protection
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 7 days(7 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 3 filings · 3 states

View merged incident ↗

Montana State AGMar 9 · first

Massachusetts State AG+7d

New Hampshire State AG+7d · this page

Pattern: first filing Mar 9 (MT), last Mar 16 (NH) — a 7-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/clarfeld-financial-20180316.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Mar 16, 2018
Raw hash: 2c27ed62be9e3e2d75e8b85f8656594c5b0b1d07ac77ecdd93c021d39b3a6aea

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityCLARFELD FINANCIAL ADVISORS, LLC

Incidentdiscovered Mar 9, 2018

Stated responseSchwab Security Administration Center identified the unauthorized access and deactivated the intruder's compromised credentials

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov