HackingTechnologyInformationStolen CredentialsCustomer Data InvolvedTargetedIdentity (basic)Government IDMediumContained

TractManager Holdings LLC

bd_cbd1f37fe316955a · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jan 18, 2021

Filed

Mar 12, 2021

To disclose

8 weeks

Affected

1state residents only

Linked

3 filings

Confidence

66%

Full breach record for TractManager Holdings LLC →

TractManager Holdings LLC (now symplr) notified the NH AG of an unauthorized access to employee email mailboxes occurring on or about September 11, 2020. The incident was discovered on January 18, 2021. One New Hampshire resident's name, address, and SSN were potentially accessed. TractManager terminated access, reset passwords, and provided 12 months of credit monitoring via Experian.

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Incident timeline

undetected · 129 days

discovery → filing · 8 weeks / 53 days

Sep 11, 2020

Begins

Jan 18, 2021

Discovered

Mar 12, 2021

Filed

vs. sector median

11 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_33e1264dc42618982021-03-05 · +7dVerified
Indiana State AGbd_d5cb85f12713ce272021-03-05 · +7dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: TractManager Holdings LLC
norm: tractmanager holdings
Industry: Technologyllm

Discovered: Jan 18, 2021
Breach occurred: Sep 11, 2020
Undetected for: 129 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 5, 2021
Affected individuals: 1state-resident count only
Data types: Identity (basic)Government ID
Attack vector: Unauthorized Access
MITRE ATT&CK: T1114 Email CollectionT1078 Valid Accounts
Threat actor: External
Initial access: valid_credentials

During the incident: Terminated any unauthorized access
Investigated the scope of the incident
Reset old passwords and changed email access procedures
Reviewing its existing policies and procedures and implementing additional safeguards
Providing access to credit monitoring services for twelve (12) months, through Experian
Changes made: Reviewing its existing policies and procedures and implementing additional safeguards to enhance the security of information in its possession
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 8 weeks(53 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 AGMar 5 · first

Indiana State AGMar 5 · first

New Hampshire State AG+7d · this page

Pattern: first filing Mar 5 (MA), last Mar 12 (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/tractmanager-holdings-20210312.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Mar 12, 2021
Raw hash: 8e16bafb298e424ddf0c866d6611a12570a88cb68a5d736ed46e9bddd72b73e7

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityTractManager Holdings LLC

Incidentdiscovered Jan 18, 2021

Stated responseTerminated any unauthorized access

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov