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State AGConfirmed3 filings · 2 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforcedhigh sensitivity
Merged incident · 3 filings

TD Bank, National Association — May 2024 breach

Clustered 3 filings across 2 jurisdictions · filing window Apr 9, 2025 → Apr 14, 2025. View entity profile → Other incidents for this victim →

⚠ 1 cross-filing discrepancy →Merge100%

Determination

Confirmed

Members

3 filings

States

2

Affected · reported

not comparable

First → last filing

Apr 9, 2025 → Apr 14, 2025

Merge confidence

100%

incident inc_f1897570e72f430e · merged by deterministic · confidence 100%

Confirmed breach. Merged as one breach: 3 regulatory filings. The filings describe an insider incident. Intrusion May 1, 2024–Dec 11, 2024, discovered Dec 11, 2024 — the first regulatory filing landed 119 days later (flagged late). Data reported: Government ID, Identity (basic), Financial account, and 2 more. Notifications rolled out on a 5-day schedule across 3 filings beginning Apr 9, 2025. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Notification delay
119days

Discovered → first regulatory filing

Filing span
5days

Time between earliest and latest filing

Not recorded for this incident

Discovery variance · Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster; needs two dated filings.

Regulatory clocksVermont✗ VT AG >45 bdayMassachusetts✓ MA credit monitoring dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

May 1, 2024breach begins
Dec 11, 2024discovered
notification delay · 119 days
Apr 9, 2025first filing
Apr 14, 2025most 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. APR 9VT AGVT AG noticefirst filing · 1 VT residentsday 0
  2. APR 10VT AGVT AG notice2 VT residents+1d
  3. APR 14MA AGMA AG noticemost recent · 15 MA residents+5d
  4. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
May 1, 2024 – May 31, 2024
VT AG
Discovered
Dec 11, 2024· 224d undetected
VT AG
Data types
Behavior · Financial account · Identity (basic) · Government ID · PCI
VT AG + MA AG
Attack vector
Insider
VT AG

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

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 filing3 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
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

5 days

Cadence

~1 / 2.5d

vs. multi-state median

1.6× faster

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

The Disclosure Clock is a weekly briefing on what landed in the disclosure record, and the gap between the criminals' post and the regulator's filing — measured on the whole record, with the method shown.

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