AccidentalFinancial ServicesFinanceMisconfigurationCustomer Data InvolvedDelayed DiscoveryIdentity (basic)Government IDMediumResolved

TCM Bank, N.A.

bd_7446f7fd9f5d27dd · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jul 16, 2018

Filed

Aug 6, 2018

To disclose

21 days

Affected

Not disclosed

Linked

2 filings

Confidence

65%

TCM Bank, N.A. notified California residents that a misconfiguration on a third-party hosted website exposed personal information, including names, addresses, Social Security numbers, and dates of birth. The misconfiguration occurred between March 5, 2017, and July 17, 2018. TCM Bank became aware of the issue on July 16, 2018. The vendor corrected the issue and implemented additional controls. Affected individuals were offered one year of complimentary credit monitoring.

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California clockDiscovered Jul 16, 2018 → Notified Aug 3, 201818d ✓ CA 60-day OK21 days discovery → filing

Incident timeline

undetected · 498 days

discovery → filing · 21 days

Mar 5, 2017

Begins

Jul 16, 2018

Discovered

Aug 6, 2018

Filed

vs. sector median

5 wks faster

This filing is one of 2 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

New Hampshire State AGbd_fd874ccaeedf88622018-08-03 · +3dVerified

Name: TCM Bank, N.A.
norm: tcm bank

Name: TCM Bank, N.A.
norm: tcm bank
Industry: Financial Servicesllm

Discovered: Jul 16, 2018
Breach occurred: Mar 5, 2017 – Jul 17, 2018
Undetected for: 498 daysoccurrence → discovery
Materiality determined: —
Notification sent: Aug 3, 2018
Affected individuals: Not disclosed
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Misconfiguration
Regulator citations: Filed notification with California Attorney General
Third party: via Third-party vendor

During the incident: Alerted the third-party vendor
Worked with the vendor to determine how the incident occurred
Worked with the vendor to determine whose personal information may have been accessible
Required that the third-party vendor employ technologies, procedures and controls to detect and prevent future similar issues
Required that the third-party vendor provide employee awareness training
Offering complimentary one-year membership in Experian IdentityWorks Credit 3B
Changes made: Corrected the issue with the website
Required third-party vendor to employ technologies, procedures and controls to detect and prevent future similar issues
Required third-party vendor to provide employee awareness training
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 21 days(21 days from discovery to filing)
Compliance flags: CA 60-day OK · 18d
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.
Clock breakdown: Statute Window Elapsed Threshold Status
California
Discovered: Jul 16, 2018
→ Notified: Aug 3, 2018
18d 60 days (analyst band, pre-2026 discoveries) CA 60-day OK

Statute	Window	Elapsed	Threshold	Status
California	Discovered: Jul 16, 2018 → Notified: Aug 3, 2018	18d	60 days (analyst band, pre-2026 discoveries)	CA 60-day OK

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings · 2 states

View merged incident ↗

New Hampshire State AGAug 3 · first

California State AG+3d · this page

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://oag.ca.gov/ecrime/databreach/reports/sb24-138586
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Aug 6, 2018
Raw hash: 980b83f86463c6ef785bec67a5d104c1fe5fc262c11635588e136daa298d929f

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityTCM Bank, N.A.

Victim entityTCM Bank, N.A.

Incidentdiscovered Jul 16, 2018

Stated responseAlerted the third-party vendor

ComplianceCA 60-day OK

Extraction provenanceno artifact recorded

Source provenanceoag.ca.gov