AccidentalFinancial ServicesFinanceMisconfigurationCustomer Data InvolvedIdentity (basic)Government IDMediumContained

TCM Bank, N.A.

bd_821991505c0b0fb2 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jul 16, 2018

Filed

Aug 3, 2018

To disclose

18 days

Affected

4state residents only

Linked

3 filings

Confidence

64%

TCM Bank, N.A. notified individuals of a data incident caused by a third-party vendor's website misconfiguration. The misconfiguration, active from March 2017 to July 2018, exposed personal information including names, addresses, SSNs, and dates of birth. TCM Bank alerted the vendor, remediated the issue, and offered one year of credit monitoring.

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Incident timeline

undetected · 498 days

discovery → filing · 18 days

Mar 5, 2017

Begins

Jul 16, 2018

Discovered

Aug 3, 2018

Filed

vs. sector median

6 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_8f3908f88c6402cc2018-08-03Verified
New Hampshire State AGbd_d280f40c04b4918c2018-08-03Verified

Name: North American Power and Gas, LLC
norm: north american power and gas

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: 4state-resident count only
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Misconfiguration
MITRE ATT&CK: T1190 Exploit Public-Facing Application

During the incident: Alerted the third-party vendor
Working with the vendor to determine how the incident occurred
Required the third-party vendor to employ technologies, procedures and controls to detect and prevent future similar issues
Provided employee awareness training
Offered complimentary one-year membership in Experian IdentityWorks Credit 3B
Changes made: Corrected the issue with the website
Required the third-party vendor to employ technologies, procedures and controls to detect and prevent future similar issues with the website
Provided employee awareness training
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 days(18 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 ↗

Massachusetts State AGAug 3 · first

New Hampshire State AGAug 3 · first

Montana State AGAug 3 · first · 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://dojmt.gov/wp-content/uploads/TCM-Bank.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Aug 3, 2018
Raw hash: 3de215460f073480e51669d539d5ba7d5258f9d5cfb3770c41aa7b50c692472d

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityNorth American Power and Gas, LLC

Victim entityTCM Bank, N.A.

Incidentdiscovered Jul 16, 2018

Stated responseAlerted the third-party vendor

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancedojmt.gov