HackingFinancial ServicesFinancePhishingStolen CredentialsCustomer Data InvolvedData ExfiltratedIdentity (basic)Government IDFinancial accountHighContained

Unified Trust Company, N.A.

bd_8c021dae427df9fd · schema v1 · pii pii-v1

Severity

High

Discovered

Feb 13, 2018

Filed

Nov 13, 2018

To disclose

39 weeks

Affected

1,111state residents only

Linked

6 filings

Confidence

66%

Full breach record for Unified Trust Company, N.A. →

Unified Trust Company, N.A. notified the NH Attorney General of unauthorized access to two employee email accounts between Dec 6, 2017 and Feb 25, 2018. Discovered Feb 13, 2018. Affected data included names, DOBs, addresses, SSNs, and financial account numbers. 1,111 NH residents notified on Nov 7, 2018. Response included forensic investigation, password resets, MFA implementation, and credit monitoring.

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Incident timeline

undetected · 69 days

discovery → filing · 39 weeks / 273 days

Dec 6, 2017

Begins

Feb 13, 2018

Discovered

Nov 13, 2018

Filed

vs. sector median

+31 wks slower

This filing is one of 6 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (5) · sorted by filing gap

South Carolina State AGbd_4cb740f3d6c5b80a2018-11-13Verified
Massachusetts State AGbd_42ed6c5382ac2c0c2018-11-07 · +6dVerified
California State AGbd_a071eca79b11746c2018-11-07 · +6dVerified
Washington State AGbd_b63082d9bea2b6592018-11-07 · +6dCandidate

Show 1 more filing ↓up to 15d gap

California State AGbd_97a5dddf0eeca1692018-11-28 · +15dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: Unified Trust Company, N.A.
norm: unified trust company na
Industry: Financial Servicesllm

Discovered: Feb 13, 2018
Breach occurred: Dec 6, 2017 – Feb 25, 2018
Undetected for: 69 daysoccurrence → discovery
Materiality determined: —
Notification sent: Nov 7, 2018
Affected individuals: 1,111state-resident count only
Data types: Identity (basic)Government IDFinancial account
Data elements: Social Security numberDate of birth
Attack vector: Phishing
MITRE ATT&CK: T1566.002 Spearphishing LinkT1078 Valid AccountsT1114 Email Collection
Threat actor: ExternalFinancial
Regulator citations: reported this incident to, and has been cooperating with, their primary federal regulator, the Office for the Comptroller of the Currency (the "OCC")notifying other state regulators and the consumer reporting agencies
Initial access: phishing_link

During the incident: Launched an internal investigation with the assistance of third-party forensic investigators
Ensuring that passwords for the affected email accounts were changed
Implemented multi-factor authentication
Enhanced security procedures around client accounts
Providing additional training to users on how to identify phishing scams
Providing potentially affected individuals access to 12 months of credit monitoring and identity restoration services through AllClear ID
Reported this incident to, and has been cooperating with, their primary federal regulator, the Office for the Comptroller of the Currency (the "OCC")
Notifying other state regulators and the consumer reporting agencies
Changes made: Implemented multi-factor authentication
Enhanced security procedures around client accounts
Provided additional training to users on how to identify phishing scams
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 39 weeks(273 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 6 filings · 5 states

View merged incident ↗

Massachusetts State AGNov 7 · first

California State AGNov 7 · first

Washington State AGNov 7 · first

South Carolina State AG+6d

New Hampshire State AG+6d · this page

California State AG+21d

Pattern: first filing Nov 7 (MA), last Nov 28 (CA) — a 21-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/utc-20181113.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Nov 13, 2018
Raw hash: 2a3a67e1e6ca6b3ebc9f0fca4beca4be84973c0cf96b04448ba3c34e726f04a5

Linked disclosures

Regulatory filings (5) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityUnified Trust Company, N.A.

Incidentdiscovered Feb 13, 2018

Stated responseLaunched an internal investigation with the assistance of third-party forensic investigators

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov