AccidentalFinancial ServicesFinanceMisdeliveryCustomer Data InvolvedIdentity (basic)Government IDMediumResolved

Flywheel Exchange

bd_f3fcb4e66a976554 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Apr 5, 2019

Filed

Apr 12, 2019

To disclose

7 days

Affected

1state residents only

Linked

2 filings

Confidence

65%

Full breach record for Flywheel Exchange →

Flywheel Exchange LLC inadvertently disclosed members' names and SSNs via password-protected K-1 statements sent to California state tax filings in April 2019. The error was discovered on April 5, 2019. Flywheel engaged legal counsel, sent amended K-1s, and provided 24 months of Experian identity protection. No crime was involved.

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Incident timeline

discovery → filing · 7 days

Apr 5, 2019

Begins

Apr 5, 2019

Discovered

Apr 12, 2019

Filed

vs. sector median

7 wks faster

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

Massachusetts State AGbd_6f62f19d31f582f92019-04-12Candidate

Name: Flywheel Exchange
norm: flywheel exchange

Name: Flywheel Exchange
norm: flywheel exchange
Industry: Financial Servicesllm

Discovered: Apr 5, 2019
Breach occurred: Apr 5, 2019
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: Apr 12, 2019
Affected individuals: 1state-resident count only
Data types: Identity (basic)Government ID
Data elements: Social Security number
Attack vector: Misconfiguration
MITRE ATT&CK: T1119 Automated Collection
Regulator citations: Notified Montana Office of the Commissioner of Insurance and Securities

During the incident: Launched an internal investigation
Retained a leading cybersecurity law firm to assist us in our investigation
Working with the accounting firm responsible for generating the K-1 disclosures
Sending out amended K-1 statements
Arranged to have Experian protect your identity for 24 months at no cost to you
Changes made: Working with the accounting firm responsible for generating the K-1 disclosures to understand how and why this occurred and to prevent future disclosures of this nature
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 7 days(7 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings · 2 states

View merged incident ↗

Massachusetts State AGApr 12 · first

Montana State AGApr 12 · 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/OCP/CON-Flywheel-Template-C1.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 12, 2019
Raw hash: 84c3cb2b768f1f893785a8766d8136c47eb1358b545cdf4015f7a4c60d1b0174

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityFlywheel Exchange

Victim entityFlywheel Exchange

Incidentdiscovered Apr 5, 2019

Stated responseLaunched an internal investigation

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancedojmt.gov