Safe Senior Financial Protection Act
Guidelines for assisting vulnerable adults at risk of financial exploitation or fraud
You should be concerned if any of the following red flags of possible exploitation or fraud are present:
- Person accompanying vulnerable adult shows excessive interest in their finances or accounts, does not allow them to speak, is reluctant to leave their side during conversations, or restricts visits or phone calls.
- Vulnerable adult shows an unusual degree of fear, anxiety, submissiveness or deference toward person accompanying him or her.
- Individual lacks knowledge about their financial status or shows a reluctance to discuss financial matters.
- Moves away from existing relationships and toward new associations with other “friends” or strangers.
- You are unable to speak directly with the vulnerable adult despite repeated attempts to contact them.
- Vulnerable adult displays unexplained or unusual excitement over a financial windfall or prize check; may be reluctant to discuss details.
- Noticeable neglect or decline in appearance, grooming, or hygiene.
- Sudden appearance of previously un-involved relatives claiming their rights to the vulnerable adult’s affairs and possessions.
Suspicious account activity
- A new caretaker, relative or friend suddenly begins conducting financial transactions on behalf of a vulnerable adult without proper documentation or through a sudden change of Power of Attorney.
- Abrupt changes to financial documents,such as power of attorney, account beneficiaries, wills, trusts, property titles, and deeds.
- Uncharacteristic nonpayment for services, which may indicate a loss of funds or access to funds Closing of accounts without regard to penalties.
- Noticeable change in vulnerable adult’s established banking or financial management habits or patterns, including:
- Frequent large withdrawals
- Sudden NSF activity
- Inconsistent transactions
- Uncharacteristic attempts to wire large sums of money
- Change of address on accounts to new recipient’s address, especially when distant from the vulnerable adult’s home
- Large withdrawals from a previously inactive account or a new joint account, or a sudden appearance of credit card balances
- Suspicious signatures
- Unexplained disappearance of funds or valuable possessions
Quick Response Reference
If you are suspicious:
- Inquire about the activity if inconsistent with consumer’s normal behavior
- Suggest an alternative to large cash withdrawals
- Make consumer aware of ways to limit risk of joint accounts
- Check documentation of the third party (e.g., power of attorney)
- Contact the appropriate person in your compliance department
If the vulnerable adult is with the suspected coercer:
- Separate the vulnerable adult from the suspect by ushering them to another location on the pretense of discussing private account information
- Contact the appropriate personnel at your firm
If you fear the vulnerable adult is in immediate danger:
- Always contact the appropriate personnel at your firm who will decide next steps