MalwareFinancial ServicesFinanceRansomwareStolen CredentialsData ExfiltratedData EncryptedCustomer Data InvolvedMulti-Stage ChainIdentity (basic)Government IDFinancial accountHighActive

LOWER, LLC

bd_fe440dee34e1a9c5 · schema v1 · pii pii-v1

Severity

High

Discovered

Dec 14, 2021

Filed

May 27, 2022

To disclose

23 weeks

Affected

3,806state residents only

Linked

15 filings

Confidence

70%

Full breach record for LOWER, LLC →4 incidents on file

Lower LLC, a financial services entity, reported a ransomware incident where unauthorized actors accessed the network between Dec 10-14, 2021, exfiltrating files and encrypting data. The breach affected names, SSNs, DOBs, driver's licenses, and financial account numbers. Lower LLC notified law enforcement, engaged forensic specialists, and provided credit monitoring to affected individuals. This filing is a supplemental notice dated Oct 6, 2022.

J jump to incidentP pin to compareR raw source

Washington clock✗ WA AG >90d23 weeks discovery → filing

Incident timeline

undetected · 4 days

discovery → filing · 23 weeks / 164 days

Dec 10, 2021

Begins

Dec 14, 2021

Discovered

May 27, 2022

Filed

vs. sector median

+15 wks slower

This filing is one of 15 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (10) · sorted by filing gap

Maine State AGbd_118024ac8e485c732022-05-27Verified by operator
California State AGbd_2dad5330357429422022-05-27Verified by operator
New Hampshire State AGbd_684eb1dfac2ece3f2022-05-31 · +4dVerified by operator
Maine State AGbd_2514e4cd772871022022-08-02 · +67dVerified by operator

Show 6 more filings ↓up to 137d gap

Oregon State AGbd_7c08e1ba6cee05ac2022-08-02 · +67dVerified by operator
California State AGbd_c89bacdc828a3dc32022-08-02 · +67dVerified by operator
New Hampshire State AGbd_6797c8aa28eb91e02022-08-08 · +73dVerified by operator
California State AGbd_625459f82668599b2022-10-06 · +132dVerified by operator
Delaware State AGbd_71783a8d00bb95792022-10-06 · +132dVerified by operator
New Hampshire State AGbd_a70e920b76c1dd242022-10-11 · +137dVerified by operator

Showing first 10 of 14 linked disclosures.

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: LOWER, LLC
norm: lower
Industry: Financial Servicesllm

Discovered: Dec 14, 2021
Breach occurred: Dec 10, 2021 – Dec 14, 2021
Undetected for: 4 daysoccurrence → discovery
Materiality determined: —
Notification sent: Jan 14, 2022
Affected individuals: 3,806state-resident count only
Data types: Identity (basic)Government IDFinancial account
Data elements: NameSocial Security numberDriver's licence numberFinancial account numberDate of birth
WA-stated cause: Cyberattack
WA-stated duration: lifecycle 1-99dexposure 1-99d
WA-stated discovery: Found after the fact
Attack vector: Ransomware
MITRE ATT&CK: T1486 Data Encrypted for ImpactT1041 Exfiltration Over C2 ChannelT1078 Valid Accounts
Threat actor: ExternalFinancial
Regulator citations: notifying regulatory authorities as required by lawproviding written notice of this incident to relevant state regulatorssupplemental notice to the three major credit reporting agencies
Initial access: valid_credentials

During the incident: Launched an in-depth investigation with the assistance of third-party forensic specialists
Notified law enforcement
Notifying regulatory authorities
Notifying potentially affected individuals
Arranged to have Experian provide credit monitoring services
Reviewing existing policies and procedures and implementing additional safeguards
Changes made: Reviewing existing policies and procedures and implementing additional safeguards to further secure the information in its systems
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 23 weeks(164 days from discovery to filing)
Compliance flags: WA AG >90d
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 11 filings · 6 states

View merged incident ↗

Maine State AGMay 27 · first

California State AGMay 27 · first

Washington State AGMay 27 · first · this page

New Hampshire State AG+4d

Maine State AG+67d

Oregon State AG+67d

California State AG+67d

New Hampshire State AG+73d

California State AG+132d

Delaware State AG+132d

New Hampshire State AG+137d

Pattern: first filing May 27 (ME), last Oct 11 (NH) — a 137-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Cascade drawn from the first 10 linked disclosures of 14 — the full spread may be wider.

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://agportal-s3bucket.s3.amazonaws.com/databreach/BreachA10466.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: May 27, 2022
Raw hash: 4c9d53b6a53f709af99e9432be82a04792808c2ac20a835cbf22cba892cbfb17

Linked disclosures

Regulatory filings (10) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityLOWER, LLC

Incidentdiscovered Dec 14, 2021

Stated responseLaunched an in-depth investigation with the assistance of third-party forensic specialists

ComplianceWA AG >90d

Extraction provenanceno artifact recorded

Source provenanceagportal-s3bucket.s3.amazonaws.com