DisclosureLens
State AGConfirmed8 filings · 7 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 8 filings

Strategic Benefits Advisors, Inc. — September 2021 breach

Clustered 8 filings across 7 jurisdictions · filing window Oct 19, 2021 Nov 12, 2021. View entity profile → Other incidents for this victim →

Determination

Confirmed

Members

8 filings

States

7

Affected · reported

58,431

First → last filing

Oct 19, 2021 Nov 12, 2021

Merge confidence

100%

incident inc_73aa5258e05943d1 · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 8 regulatory filings. Intrusion Sep 18, 2021, discovered Sep 19, 2021 — the first regulatory filing landed 30 days later. 58,431 individuals reported across the linked filings. Data reported: Government ID, Identity (basic), and PII. Notifications rolled out on a 24-day schedule across 8 filings beginning Oct 19, 2021. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
30days

Discovered → first regulatory filing

Discovery variance
22days

Range of discovered_at dates across filings

Filing span
24days

Time between earliest and latest filing

Not recorded for this incident

Leak precedence · Materiality delta · SEC filing delayno leak-site claim in this cluster; no SEC 8-K in this cluster.

Regulatory clocksMaine ME AG >30d · 32dMassachusetts MA credit monitoring dueCalifornia CA 60-day OK · 47dSouth Carolina SC CRA notice dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Sep 18, 2021breach begins
Sep 19, 2021discovered · members disagree
notification delay · 30 days
Oct 19, 2021first filing
Nov 12, 2021most recent filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident.

Member cascade — every filing about this breach

  1. OCT 19IN AGIN AG noticefirst filing · states nationwide total 36,047day 0
  2. OCT 28ME AGME AG noticestates nationwide total 36,047+9d
  3. OCT 28MA AGMA AG notice144 MA residents+9d
  4. NOV 1NH AGNH AG notice38 NH residents+13d
  5. NOV 5CA AGCA AG noticeno count stated+17d
  6. NOV 8SC AGSC AG notice1,732 SC residents+20d
  7. NOV 12ME AGME AG noticestates nationwide total 58,431+24d
  8. NOV 12MT AGMT AG noticemost recent · 40 MT residents+24d
  9. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Sep 18, 2021
IN AG
Discovered
Sep 19, 2021NH AG + CA AG + SC AG +1Oct 11, 2021ME AGfilings disagree on discovery
Data types
Identity (basic) · Government ID · PII
ME AG + MA AG + NH AG +3
Attack vector
Unauthorized Access
ME AG

Each fact cites the member filing that establishes it; when filings conflict, every value shows with its source.

Count reconciliation

per-state reported counts

Nationwide (stated in a filing)

58,431

Sum of filed state slices

2,544· 4.4% of stated

96% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US58,431
SC1,732
IN494
MA144
ME96
MT40
NH38

State AGs report only their own residents; teal bars show each state's reported slice. The gray US row is the nationwide total reported in a linked filing.

Evidence ladder — rungs this incident occupies

Leak-site claim

No leak-site claim on record for this incident.

Press / market report

No press coverage linked yet.

State AG / regulator filing8 members

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

No SEC filing or victim statement yet.

Merge provenance

Method
deterministic
Confidence
1.00 · above the 0.85 auto-merge floor
Reviewed
operator-reviewed Jun 12, 2026 · at least one link edge was human-adjudicated
Audit
Every link edge records its method, confidence and model + prompt versions (100% is the strongest edge).

Merges are reversible — a wrong link can be detached with its audit trail intact. How merging works.

Filing velocity

Spread

24 days

Cadence

~1 / 3.4d

vs. multi-state median

3.0× slower

About this clustering

DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. This page states only what the linked filings agree on; each filing's own account stays on its own record, linked from the timeline below.

The weekly clock on records like this one

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