Social EngineeringFinancial ServicesTechnologyFinancePhishingData ExfiltratedCustomer Data InvolvedIdentity (basic)Government IDHighContained

flexPATH Strategies

bd_0172292eef70ab30 · schema v1 · pii pii-v1

Severity

High

Discovered

Dec 14, 2018

Filed

Mar 15, 2019

To disclose

13 weeks

Affected

1,573state residents only

Linked

9 filings

Confidence

66%

Full breach record for flexPATH Strategies →

flexPATH Strategies, LLC, a retirement plan adviser, reported a phishing incident in Hawaii where an employee's email account was compromised on Dec 7, 2018. The breach exposed names and SSNs of 1,573 Hawaii residents. flexPATH secured the account, engaged forensic investigators, and provided credit monitoring services. This filing is a supplemental notification to the Hawaii Office of Consumer Protection.

J jump to incidentP pin to compareR raw source

Hawaii clock✓ HI CRA notice due13 weeks discovery → filing

⚠ unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Incident timeline

undetected · 7 days

discovery → filing · 13 weeks / 91 days

Dec 7, 2018

Begins

Dec 14, 2018

Discovered

Mar 15, 2019

Filed

vs. sector median

+5 wks slower

This filing is one of 9 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (8) · sorted by filing gap

Montana State AGbd_5c77e09d3d33f3b82019-03-15Candidate
Washington State AGbd_7a883bef71700ef02019-03-15Verified
California State AGbd_956af0e49a3ab8c02019-03-15Verified
Oregon State AGbd_be14e8f992f427b82019-03-15Verified

Show 4 more filings ↓up to 34d gap

Massachusetts State AGbd_fe1e38fc4db5a5a12019-03-15Verified
New Hampshire State AGbd_e09a95a83b415f782019-03-18 · +3dVerified
California State AGbd_0691b0e3d1dc7a912019-04-17 · +33dCandidate
New Hampshire State AGbd_84f1cef05ba4ccb92019-04-18 · +34dVerified

Name: BakerHostetler LLP
norm: bakerhostetler

Name: flexPATH Strategies
norm: flexpath strategies
Industry: Financial ServicesllmTechnologyllm

Discovered: Dec 14, 2018
Breach occurred: Dec 7, 2018
Undetected for: 7 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 15, 2019
Affected individuals: 1,573state-resident count only
Data types: Identity (basic)Government ID
Data elements: Social Security number
Attack vector: Phishing
MITRE ATT&CK: T1566.002 Spearphishing Link
Threat actor: External
Regulator citations: submitted initial notification to Hawaii Office of Consumer Protection on March 15, 2019submitted supplemental incident notification to Hawaii Office of Consumer Protection on April 17, 2019
Initial access: phishing_link

During the incident: Secured the employee's email account
Engaged a computer security firm to assist us
Reviewed the full contents of the account for personal information
Provided notice to the employees and retirement plan participants
Established a dedicated call center
Offered the individuals a complimentary, one-year membership to credit monitoring and identity theft protection services
Changes made: Implementing additional procedures to further expand and strengthen its security processes
Providing continued education and training to its employees
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 13 weeks(91 days from discovery to filing)
Compliance flags: HI CRA notice due
Discovery-date grounding: unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 9 filings · 7 states

View merged incident ↗

Montana State AGMar 15 · first

Washington State AGMar 15 · first

California State AGMar 15 · first

Oregon State AGMar 15 · first

Massachusetts State AGMar 15 · first

Hawaii State AGMar 15 · first · this page

New Hampshire State AG+3d

California State AG+33d

New Hampshire State AG+34d

Pattern: first filing Mar 15 (MT), last Apr 18 (NH) — a 34-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://web.archive.org/web/20211024101019id_/https://cca.hawaii.gov/ocp/files/2019/04/flexPATH-Strategies-LLC-OCP-2019-0117.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Mar 15, 2019
Raw hash: c5aeb879ce02bb354c1648949e01584890148f3bfc173bcf3f95ad9369e14985

Linked disclosures

Regulatory filings (8) · sorted by filing gap

Reporting entityBakerHostetler LLP

Victim entityflexPATH Strategies

Incidentdiscovered Dec 14, 2018

Stated responseSecured the employee's email account

ComplianceHI CRA notice due

Extraction provenanceno artifact recorded

Source provenanceweb.archive.org