The Philadelphia Financial Exploitation Prevention Taskforce recommends financial institutions add the following elements to their internal elder abuse prevention policies and practices.
- Commit to reporting in all 50 states regardless of whether financial institutions are mandatory or permissive (voluntary) reporters
- Implement education and detection programs across all lines of business (deposits, lending, credit card, mortgage, investments, trust, advice, etc.)
- Mandatory Training Program for all employees – at a minimum customer facing (all channels) and those involved in loss prevention and transaction review. Required course for new hires and annual refresh for all employees.
Subject Matter Experts
- Dedicated personnel who gain experience in the nuances of working elder cases and understand the difference between “traditional” financial fraud and financial exploitation.
- Program Manager who stays abreast of industry best practices, research, and legislative updates
- Attend APS events, join local/regional elder abuse task forces or multi-disciplinary teams
- Leverage existing resources for the financial services industry (e.g. CFPB, ABA, Financial Services Roundtable, SIFMA, NASAA, FINRA, NAPSA – each has robust materials related to financial abuse and exploitation
Prevention and Identification
- Develop data analytics to proactively identify customers at risk for exploitation
- Offer to add a trusted contact to account (or at customer’s request)
- Offer customers access or recommendations for online monitoring products (“eyes only” or 3rd party)
- Customer education on how to prevent financial exploitation (education events, articles/blogs on firm website
Request for Records
- Expedited processing for requests from APS and Law Enforcement
- Provide records to APS without need for subpoena (To degree permitted by Graham-Leach-Bliley)
- Do not alert customer(s) or fiduciaries that request for records have been received
- Provide records to APS and law enforcement without charging a fee to requesting agency or customer