Social EngineeringProfessional ServicesProfessional ServicesPhishingCustomer Data InvolvedIdentity (basic)Government IDHighContained

flexPATH Strategies

bd_7a883bef71700ef0 · schema v1 · pii pii-v1

Severity

High

Discovered

Dec 14, 2018

Filed

Mar 15, 2019

To disclose

13 weeks

Affected

1,398state residents only

Linked

9 filings

Confidence

70%

Full breach record for flexPATH Strategies →

flexPath Strategies LLC notified Washington AG of a phishing incident affecting an employee email account. Unauthorized access occurred Dec 7, 2018. 1,398 WA residents' names and SSNs were potentially exposed. Notices mailed March 15, 2019. Credit monitoring offered.

J jump to incidentP pin to compareR raw source

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

6 wks faster

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

Hawaii State AGbd_0172292eef70ab302019-03-15Verified
Montana State AGbd_5c77e09d3d33f3b82019-03-15Candidate
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: flexPATH Strategies
norm: flexpath strategies

Name: flexPATH Strategies
norm: flexpath strategies
Industry: Professional Servicesllm

Discovered: Dec 14, 2018
Breach occurred: Dec 7, 2018
Undetected for: 7 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 15, 2019
Affected individuals: 1,398state-resident count only
Data types: Identity (basic)Government ID
Data elements: NameSocial Security number
WA-stated cause: Cyberattack
WA-stated duration: lifecycle 1-99dexposure 0d
WA-stated discovery: Found after the fact
Attack vector: Phishing
MITRE ATT&CK: T1566.002 Spearphishing LinkT1078 Valid Accounts
Threat actor: External
Regulator citations: Notified Washington Attorney General
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
Reviewed the full contents of the account for personal information
Began mailing notification letters to Washington residents
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: — (clock not assessable for this source)

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

California State AGMar 15 · first

Oregon State AGMar 15 · first

Massachusetts State AGMar 15 · first

Washington 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 (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://agportal-s3bucket.s3.amazonaws.com/databreach/BreachM10619.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: 4c440cf59f165da6b0eda6251d117aae968fd074f392a0c370d82544149f2b83

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

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenanceagportal-s3bucket.s3.amazonaws.com