Protecting Your Elderly Customers from Elder Abuse
Protecting Your Elderly Customers from Elder Abuse – Is Your Defense Strong Enough?
Financial institutions are the first line of defense for identifying and reporting elder financial exploitation, one type of elder abuse, to the proper authorities. Since elder abuse may take many forms, including financial exploitation, your institution must be equipped to identify the financial abuse conducted by an elderly customer’s family member, caregiver, or new “friend.” Your institution’s four-pronged defense may preserve an elderly customer’s financial welfare and beyond:
- Training – Has your institution incorporated elder abuse red flags in required BSA training? Make sure your frontline and back office personnel are equipped to spot the red flags associated with elder abuse. Red flags may be displayed by the customer – has branch personnel noticed a change in the customer’s usual pattern of banking or has the Deposit area noticed the customer’s account has started to show increasing overdrafts? Red flags may also be displayed by an individual accompanying the customer to the branch – does this individual linger in the teller window while the transaction is conducted, speaking for the customer or showing excessive interest? Does a caregiver refuse to put the customer on the phone when your Branch Manager calls the house?
- Chain of Reporting – Once red flags are identified or suspected, do your employees know how to quickly and effectively report the information to the appropriate area in your institution? Is this process part of training? Elder abuse suspicions must be acted on timely to mitigate the financial and safety risks for the customer.
- Designation of Appropriate Point of Contact – Has your institution appointed a point of contact for reporting elder abuse to the proper authorities, including the county and/or Adult Protective Services? Is this employee working in conjunction with your institution’s BSA Department to ensure review of the activity for suspicious activity report (SAR) filing purposes?
- SAR Completion – In 2011, FinCEN issued guidance for SAR completion for elder abuse cases, directing financial institutions to include the words “Elder Financial Exploitation” in the narrative of the SAR. This language should accompany the selection of box “d” under SAR section 35 – Other suspicious Activities. The inclusion of this wording in the SAR will enable law enforcement to quickly identify elder abuse cases in need of investigation.
Since most elder abuse is perpetrated by those closest to the elderly customer, including family members, your financial institution may be that customer’s only lifeline in stopping the abuse. Make sure your institution’s line of defense is strong enough to put you in the position your elderly customers so desperately need.
For more information on FinCEN’s elder abuse guidance and common red flags, visit
http://www.fincen.gov/statutes_regs/guidance/html/fin-2011-a003.html or contact an FOS team member for additional assistance. To contact the author Julie Mixtacki email firstname.lastname@example.org.