Social EngineeringFinancial ServicesProfessional ServicesFinancePhishingStolen CredentialsCustomer Data InvolvedEmployee Data InvolvedPIIIdentity (basic)Financial accountLowContained

flexPATH Strategies

bd_0691b0e3d1dc7a91 · schema v1 · pii pii-v1

Severity

Low

Discovered

Dec 14, 2018

Filed

Apr 17, 2019

To disclose

18 weeks

Affected

Not disclosed

Linked

9 filings

Confidence

65%

Full breach record for flexPATH Strategies →

flexPATH Strategies, LLC notified the California Attorney General of a data breach involving a phishing email incident. An unauthorized person accessed an employee's email account on December 7, 2018. The company discovered the incident on December 14, 2018. Personal information, including names and potentially financial account data, was found in an email attachment. The company secured the account, engaged a security firm, and offered credit monitoring to affected individuals.

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California clockDiscovered Dec 14, 2018 → Notified Jan 25, 201942d ✓ CA 60-day OK18 weeks discovery → filing

Incident timeline

undetected · 7 days

discovery → filing · 18 weeks / 124 days

Dec 7, 2018

Begins

Dec 14, 2018

Discovered

Apr 17, 2019

Filed

vs. sector median

+9 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

New Hampshire State AGbd_84f1cef05ba4ccb92019-04-18 · +1dVerified
New Hampshire State AGbd_e09a95a83b415f782019-03-18 · +30dVerified
Hawaii State AGbd_0172292eef70ab302019-03-15 · +33dVerified
Montana State AGbd_5c77e09d3d33f3b82019-03-15 · +33dCandidate

Show 4 more filings ↓up to 33d gap

Washington State AGbd_7a883bef71700ef02019-03-15 · +33dVerified
California State AGbd_956af0e49a3ab8c02019-03-15 · +33dVerified
Oregon State AGbd_be14e8f992f427b82019-03-15 · +33dVerified
Massachusetts State AGbd_fe1e38fc4db5a5a12019-03-15 · +33dVerified

Name: flexPATH Strategies
norm: flexpath strategies

Name: flexPATH Strategies
norm: flexpath strategies
Industry: Financial ServicesllmProfessional Servicesllm

Discovered: Dec 14, 2018
Breach occurred: Dec 7, 2018
Undetected for: 7 daysoccurrence → discovery
Materiality determined: —
Notification sent: Jan 25, 2019
Affected individuals: Not disclosed
Data types: PIIIdentity (basic)Financial account
Attack vector: Phishing
MITRE ATT&CK: T1566.002 Spearphishing LinkT1078 Valid AccountsT1114 Email Collection
Threat actor: External
Initial access: phishing_link

During the incident: Secured the employee’s email account
Launched an investigation to determine the nature and scope of the incident
Engaged a computer security firm to assist us
Offering a complimentary one-year credit monitoring membership with Experian’s IdentityWorks
Changes made: Implementing additional procedures to further expand and strengthen our security processes
Providing continued education and training to our employees
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 weeks(124 days from discovery to filing)
Compliance flags: CA 60-day OK · 42d
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.
Clock breakdown: Statute Window Elapsed Threshold Status
California
Discovered: Dec 14, 2018
→ Notified: Jan 25, 2019
42d 60 days (analyst band, pre-2026 discoveries) CA 60-day OK

Statute	Window	Elapsed	Threshold	Status
California	Discovered: Dec 14, 2018 → Notified: Jan 25, 2019	42d	60 days (analyst band, pre-2026 discoveries)	CA 60-day OK

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 9 filings · 7 states

View merged incident ↗

Hawaii State AGMar 15 · first

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

New Hampshire State AG+3d

California State AG+33d · this page

New Hampshire State AG+34d

Pattern: first filing Mar 15 (HI), 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://oag.ca.gov/ecrime/databreach/reports/sb24-146426
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 17, 2019
Raw hash: 9ab4365419fce7a34f83b1498ccd5028640a7cb9b79de5f1be5b1bd9d88c95f1

Linked disclosures

Regulatory filings (8) · sorted by filing gap

Reporting entityflexPATH Strategies

Victim entityflexPATH Strategies

Incidentdiscovered Dec 14, 2018

Stated responseSecured the employee’s email account

ComplianceCA 60-day OK

Extraction provenanceno artifact recorded

Source provenanceoag.ca.gov