DisclosureLens
HackingFinancial ServicesTechnologyFinanceVulnerability ExploitZero-DayData ExfiltratedSupply Chain (3P Vendor)Customer Data InvolvedIdentity (basic)Government IDFinancial accountHighContained

Emerald Financial Services, LLC

bd_b971d316ca187164 · schema v1 · pii pii-v1

Severity

High

Discovered

Jul 12, 2023

Filed

Oct 4, 2023

To disclose

12 weeks

Affected

15,776state residents only

Linked

2 filings

Confidence

69%

FIS and Emerald Financial Services (EFS) disclosed a data security incident involving Progress Software's MOVEit Transfer tool. An unauthorized third party exploited a zero-day vulnerability to exfiltrate files containing personal information of Pathward customers, including names, SSNs, DOBs, driver's license numbers, and card account details. FIS and EFS became aware on July 12, 2023. Notifications were mailed to 15,776 Washington residents between September 26-29, 2023. Two years of credit monitoring were offered.

Washington clock WA AG >30d12 weeks discovery → filing
AG web formThe discovery date came from the AG web-form field, which is systematically later than the detection date stated in the letter. Treat the clock as indicative.

Incident timeline

discovery → filing · 12 weeks / 84 days

Jul 12, 2023

Discovered

Oct 4, 2023

Filed

vs. sector median

+4 wks slower

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

Filing propagation · 2 filings · 2 states

View merged incident ↗
Montana State AGSep 27 · first
Washington State AG+7d · this page

Pattern: first filing Sep 27 (MT), last Oct 4 (WA) — 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.