AccidentalFinancial ServicesFinanceMisconfigurationCustomer Data InvolvedDelayed DiscoveryIdentity (basic)Government IDMediumContained

TCM Bank, N.A.

bd_fd874ccaeedf8862 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jul 16, 2018

Filed

Aug 3, 2018

To disclose

18 days

Affected

32state residents only

Linked

2 filings

Confidence

66%

TCM Bank, N.A. notified the New Hampshire Attorney General of a potential data security incident affecting 32 NH residents. A third-party vendor's website misconfiguration (March 2017–July 2018) exposed names, addresses, SSNs, and DOBs. TCM Bank discovered the issue on July 16, 2018, remediated the misconfiguration, and offered 1 year of credit monitoring.

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Incident timeline

undetected · 498 days

discovery → filing · 18 days

Mar 5, 2017

Begins

Jul 16, 2018

Discovered

Aug 3, 2018

Filed

vs. sector median

6 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

California State AGbd_7446f7fd9f5d27dd2018-08-06 · +3dCandidate

Name: Polsinelli PC
norm: polsinelli

Name: TCM Bank, N.A.
norm: tcm bank
Industry: Financial Servicesllm

Discovered: Jul 16, 2018
Breach occurred: Mar 5, 2017 – Jul 17, 2018
Undetected for: 498 daysoccurrence → discovery
Materiality determined: —
Notification sent: Aug 3, 2018
Affected individuals: 32state-resident count only
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Misconfiguration
MITRE ATT&CK: T1190 Exploit Public-Facing Application
Regulator citations: Notified New Hampshire Attorney General

During the incident: Alerted the third-party vendor
Worked with the vendor to determine how the incident occurred
Obtained confirmation from the third-party vendor that the issue with the website has been corrected
Required that the third party-vendor employ technologies, procedures and controls to detect and prevent similar issues
Required that the vendor provide its employees with enhanced security awareness training
Arranged to offer one (1) year of complimentary credit monitoring and identity theft protection services through Experian
Established a confidential telephone inquiry line
Changes made: Required that the third party-vendor employ technologies, procedures and controls to detect and prevent similar issues with the website from occurring in the future
Required that the vendor provide its employees with enhanced security awareness training
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 days(18 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 ↗

New Hampshire State AGAug 3 · first · this page

California State AG+3d

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/tcm-bank-20180803.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Aug 3, 2018
Raw hash: fdd88ff6725c482f48daaea98d95076c5a3bd2c0b731c119ddfb6d14f93ffc37

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityPolsinelli PC

Victim entityTCM Bank, N.A.

Incidentdiscovered Jul 16, 2018

Stated responseAlerted the third-party vendor

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov