MisuseFinancial ServicesFinancePrivilege AbuseCustomer Data InvolvedGovernment IDIdentity (basic)HighContained

Custom Benefit Programs, Inc.

bd_2c8c6cbe418fb978 · schema v1 · pii pii-v1

Severity

High

Discovered

Apr 7, 2021

Filed

May 19, 2021

To disclose

6 weeks

Affected

11,731scope not determined

Linked

6 filings

Confidence

66%

Full breach record for Custom Benefit Programs, Inc. →

Custom Benefit Programs, Inc. (an Aon Company) reported an insider wrongdoing incident on December 17, 2020, discovered on April 7, 2021. The breach affected 11,731 individuals, compromising names and Social Security Numbers. The company provided 12 months of credit monitoring via Equifax to affected parties.

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Maine clockDiscovered Apr 7, 2021 → Filed with AG May 19, 202142d ⏱ ME AG >30d6 weeks discovery → filing

⚠ AG web formThe discovery date came from the AG web-form field, which is systematically later than the detection date stated in the letter. Treat the clock as indicative.

Incident timeline

undetected · 111 days

discovery → filing · 6 weeks / 42 days

Dec 17, 2020

Begins

Apr 7, 2021

Discovered

May 19, 2021

Filed

vs. sector median

2 wks faster

This filing is one of 6 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (5) · sorted by filing gap

Massachusetts State AGbd_1ee7dbdf471086172021-05-21 · +2dVerified
California State AGbd_2863a3cdb89a289c2021-05-21 · +2dCandidate
Indiana State AGbd_337e135fe22f35022021-05-21 · +2dVerified
Maine State AGbd_62163a93ba4b6a912021-05-21 · +2dVerified

Show 1 more filing ↓up to 2d gap

Montana State AGbd_b1d7bcd36b1fecc72021-05-21 · +2dVerified

Name: Custom Benefit Programs, Inc.
norm: custom benefit programs

Name: Custom Benefit Programs, Inc.
norm: custom benefit programs
Industry: Financial Servicesllm

Discovered: Apr 7, 2021
Breach occurred: Dec 17, 2020
Undetected for: 111 daysoccurrence → discovery
Materiality determined: —
Notification sent: May 21, 2021
Affected individuals: 11,731scope not determined
Data types: Government IDIdentity (basic)
Data elements: Social Security number
Attack vector: Insider
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: Internal
Initial access: insider_action

During the incident: Offered 12 months of credit monitoring services through Equifax
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 6 weeks(42 days from discovery to filing)
Compliance flags: ME AG >30d · 42d
Discovery-date grounding: AG web formThe discovery date came from the AG web-form field, which is systematically later than the detection date stated in the letter. Treat the clock as indicative.
Clock breakdown: Statute Window Elapsed Threshold Status
Maine
Discovered: Apr 7, 2021
→ Filed with AG: May 19, 2021
42d 30 days (soft) ME AG >30d

Statute	Window	Elapsed	Threshold	Status
Maine	Discovered: Apr 7, 2021 → Filed with AG: May 19, 2021	42d	30 days (soft)	ME AG >30d

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 6 filings · 5 states

View merged incident ↗

Maine State AGMay 19 · first · this page

Massachusetts State AG+2d

California State AG+2d

Indiana State AG+2d

Maine State AG+2d

Montana State AG+2d

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://www.maine.gov/agviewer/content/ag/985235c7-cb95-4be2-8792-a1252b4f8318/abafb623-b615-4d76-9a02-2daa6a56b580.shtml
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: May 19, 2021
Raw hash: d9872ae6106435dae8e1a238214616b60ba56e0355b4b3061f926700279df936

Linked disclosures

Regulatory filings (5) · sorted by filing gap

Reporting entityCustom Benefit Programs, Inc.

Victim entityCustom Benefit Programs, Inc.

Incidentdiscovered Apr 7, 2021

Stated responseOffered 12 months of credit monitoring services through Equifax

ComplianceME AG >30d

Extraction provenanceno artifact recorded

Source provenancewww.maine.gov