MisuseFinancial ServicesFinancePrivilege AbuseEmployee Data InvolvedTargetedIdentity (basic)Government IDFinancial accountMediumContained

Freedom Financial Network

bd_d4622d05e7718823 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Dec 1, 2019

Filed

Apr 6, 2020

To disclose

18 weeks

Affected

1state residents only

Linked

5 filings

Confidence

67%

Full breach record for Freedom Financial Network →

Freedom Financial Network, LLC notified the NH AG of a data event involving one NH resident. A former employee colluded with a third party to fraudulently claim debt ownership and transmitted personal info (name, SSN, credit card number) to the third party in Dec 2019. Freedom reported to law enforcement/FBI, implemented safeguards, and provided 1 year of credit monitoring.

J jump to incidentP pin to compareR raw source

Incident timeline

discovery → filing · 18 weeks / 127 days

Dec 1, 2019

Discovered

Apr 6, 2020

Filed

vs. sector median

+10 wks slower

This filing is one of 5 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (4) · sorted by filing gap

Montana State AGbd_57f9c3f7d8cba4902020-04-02 · +4dVerified
Massachusetts State AGbd_04896f19cfd928c92020-03-31 · +6dVerified
Montana State AGbd_ab72a5e57a33d5882020-03-31 · +6dCandidate
Indiana State AGbd_dcd973638d7d663d2020-03-31 · +6dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: Freedom Financial Network
norm: freedom financial network
Industry: Financial Servicesllm

Discovered: Dec 1, 2019
Materiality determined: —
Notification sent: Mar 31, 2020
Affected individuals: 1state-resident count only
Data types: Identity (basic)Government IDFinancial account
Data elements: Social Security number
Attack vector: Insider
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: InternalFinancial
Regulator citations: Notified Office of the New Hampshire Attorney GeneralReported matter to local law enforcement, the FBI and the Office of the Attorney General/Department of Justice
Initial access: insider_action

During the incident: Freedom reported this matter to the authorities and is actively cooperating with the prosecution
Freedom moved quickly to investigate and respond to the incident
Freedom is working to implement additional safeguards and training to its employees
Freedom is providing affected individuals whose personal information was potentially affected by this incident with access to one (1) year of credit monitoring services through Kroll at no cost to these individuals
Freedom reported this matter to local law enforcement, the FBI and the Office of the Attorney General/Department of Justice
Changes made: Freedom is reviewing its internal procedures and working to implement additional safeguards to help protect information in its possession
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 weeks(127 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 5 filings · 4 states

View merged incident ↗

Massachusetts State AGMar 31 · first

Montana State AGMar 31 · first

Indiana State AGMar 31 · first

Montana State AG+2d

New Hampshire State AG+6d · this page

Pattern: first filing Mar 31 (MA), last Apr 6 (NH) — a 6-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/freedom-financial-network-20200406.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 6, 2020
Raw hash: fc7dd71ba87947c26ad7613bff1a5d38664ecc7be81814e8f6cda329dd4bdfbe

Linked disclosures

Regulatory filings (4) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityFreedom Financial Network

Incidentdiscovered Dec 1, 2019

Stated responseFreedom reported this matter to the authorities and is actively cooperating with the prosecution

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov