UnknownMedium

flexPATH Strategies

bd_be14e8f992f427b8 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Feb 22, 2019

Filed

Mar 15, 2019

To disclose

21 days

Affected

60,862

Linked

9 filings

Confidence

95%

Full breach record for flexPATH Strategies →

flexPATH Strategies, LLC reported a data breach to the Oregon Attorney General. The breach was reported on 2019-03-15. The breach occurred during 12/7/2018 - 12/7/2018. The breach was discovered on 2/22/2019. 60,862 individuals were affected. Notice was sent on 3/15/2019.

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Oregon clock✓ OR AG ≤45d21 days 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 · 77 days

discovery → filing · 21 days

Dec 7, 2018

Begins

Feb 22, 2019

Discovered

Mar 15, 2019

Filed

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
Washington State AGbd_7a883bef71700ef02019-03-15Verified
California State AGbd_956af0e49a3ab8c02019-03-15Verified

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

Discovered: Feb 22, 2019
Breach occurred: Dec 7, 2018
Undetected for: 77 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 15, 2019
Affected individuals: 60,862nationwide
Data types: —
Attack vector: Unknown

Time to disclose: 21 days(21 days from discovery to filing)
Compliance flags: OR AG ≤45d
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.

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

Massachusetts State AGMar 15 · first

Oregon 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://justice.oregon.gov/consumer/DataBreach/
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: 341b4cb7c1e6c5b8e65ab308ceb6480d4fbd2ffd3aea6f18b4254b5d22e28403

Linked disclosures

Regulatory filings (8) · sorted by filing gap

Reporting entityflexPATH Strategies

Victim entityflexPATH Strategies

Incidentdiscovered Feb 22, 2019

ComplianceOR AG ≤45d

Extraction provenanceno artifact recorded

Source provenancejustice.oregon.gov