Official Case FileNH · Sep 22, 2025

Commonwealth Trust Company Data Security Incident

Investigation Open

Reported to the NH Attorney General on September 22, 2025.

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§ I

Incident Overview

Financial institutions like Commonwealth Trust Company are prime targets because of the direct access their records provide to victims' assets. According to a NH state filing, Commonwealth Trust Company experienced a data security incident affecting an undisclosed number of individuals, exposing Social Security Numbers and financial account data. Legal proceedings relating to this breach are ongoing.

The financial services industry is subject to some of the most stringent data protection requirements in the country, including state-level breach notification laws and federal standards under the Gramm-Leach-Bliley Act. Despite these requirements, Commonwealth Trust Company experienced a breach that exposed sensitive customer data. Affected customers have grounds to seek accountability under both New Hampshire data breach notification law and applicable federal statutes.

§ II

Case Facts & Filing Record

State Filed
NH
Date Reported to AG
Sep 22, 2025
Date of Breach
Not disclosed
Records Affected
Not disclosed
Filing Status
Investigation Open
Last Updated
Jul 21, 2026
Data Types Exposed(inferred from industry — not specified in filing)
Financial AccountSSNDate of BirthAddressEmail
§ III

Risk Analysis — Exposed Data

This filing does not specify data types. Based on Commonwealth Trust Company's industry, the following risks are commonly associated with similar breaches:

Financial Fraudcritical

Exposed bank and card information allows direct account draining, unauthorized purchases, and fraudulent wire transfers. Act immediately if you notice unfamiliar charges.

Identity Theftcritical

Exposed Social Security Numbers can be used to open fraudulent credit accounts, file false tax returns, and commit federal benefits fraud — often for years before detection.

Identity Verification Bypassmedium

Combined with a name and other leaked data, date of birth helps criminals pass identity verification questions at banks and government agencies.

Physical Security Riskmedium

Home address exposure can enable mail theft, package fraud, and targeted phishing attacks that reference your known location.

Targeted Phishingmedium

Your email being connected to this breach makes you a high-value phishing target. Watch for impersonation attempts referencing the company or the breach.

§ IV

Check Your Eligibility

Under the New Hampshire data breach notification law, you may have a legal claim against Commonwealth Trust Company if any of the following apply:

  • You received a written data breach notification letter from Commonwealth Trust Company
  • You are or were a customer, patient, or employee of Commonwealth Trust Company
  • Your information was held by Commonwealth Trust Company in NH
  • Your Social Security Number may have been compromised
  • Your bank or payment card data was potentially exposed

Applicable law: This breach was reported under the New Hampshire data breach notification law, which establishes your right to seek damages from Commonwealth Trust Company.

§ V

Your Legal Rights — Compensation Available

01
Lost Time & Remediation Costs

The hours spent responding to a data breach — canceling accounts, contacting credit bureaus, updating passwords, and investigating fraud — represent compensable economic harm in data breach litigation.

02
Identity Theft Protection Costs

Once your SSN is exposed, protection becomes an ongoing expense. Plaintiffs in data breach settlements have recovered costs for credit freezes, identity protection subscriptions, and time spent dealing with fraudulent accounts — sometimes covering multiple years of exposure.

03
Banking & Account Fees

Fees charged to close and reopen accounts, issue replacement cards, or dispute fraudulent transactions are recoverable in data breach litigation. So are the costs of overdrafts, late payments, and credit damage caused by unauthorized activity.

04
Statutory Minimum Damages

Several state data breach laws provide for statutory minimum damages — fixed amounts recoverable per affected individual regardless of actual loss. These provisions exist specifically to make legal action viable for victims who have not yet experienced direct harm.

§ VI

Frequently Asked Questions

Do I need proof that my data was misused to file a claim against Commonwealth Trust Company?

No. Under New Hampshire data breach notification law and federal law, the unauthorized exposure of your personal data — regardless of whether it has been actively misused — can be sufficient grounds for a claim. The breach itself is the injury.

How much does filing a claim cost?

Nothing. The Law Office of David S. Harris handles data breach cases on contingency — you pay zero upfront and owe nothing unless compensation is recovered.

My Social Security Number was exposed. What should I do right now?

Immediately place a free credit freeze at all three bureaus (Equifax, Experian, TransUnion). A freeze blocks new accounts from being opened in your name. Then file a complaint with the FTC at IdentityTheft.gov and contact our office — SSN exposure is one of the most serious breach types.

My financial account data was exposed. Can the bank recover my losses?

Banks may reverse fraudulent charges, but they are not obligated to compensate you for time lost, stress, or indirect damages. A class action claim against the breached company can recover those additional categories of harm.

Is it too late to file a claim?

Statutes of limitations for data breach claims vary by state but typically run 2–4 years. Depending on when you learned of the breach, you may still have time. Contact our office for a free eligibility review — there is no cost to find out.

What if Commonwealth Trust Company offered me free credit monitoring after the breach?

Accepting free credit monitoring from Commonwealth Trust Company does not waive your right to pursue legal action unless you signed a specific release waiving claims. In most cases, victims who accepted monitoring can still file.

Do I need to have received a notice letter to be eligible?

Not necessarily. Many data breach victims are never notified directly. If your personal information was held by Commonwealth Trust Company during the relevant period, you may still qualify even without receiving a letter. A free eligibility review can confirm your status.

Received a notification letter from Commonwealth Trust Company?

Read our dedicated guide — what the letter means and exactly what to do.

Read Letter Guide →
§ VII

Submit Your Free Case Review

If you were affected by the Commonwealth Trust Company data breach, you may be entitled to compensation. Submit your information below for a free attorney review — no obligation, no upfront cost.

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Source: State Attorney General filing, NH

View Official AG Filing →

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