An area of growing significance to regulators is elder abuse. The latest sign arrived on July 17, 2019, when the Consumer Financial Protection Bureau (CFPB) issued an updated advisory to financial institutions urging them to notify authorities when they suspect the financial exploitation of older adults (elder abuse). The update to the 2016 advisory is 25 pages long and is a must read for financial institutions. The update focuses on the need to report all cases of elder abuse to relevant federal, state and local authorities. It highlights the CFPB recommendation to file Suspicious Activity Reports (SARs) when a financial institution suspects elder abuse. The advisory also recommends that financial institutions work with their legal counsel in expediting their response to requests for SAR supporting documentation by law enforcement. Finally, the advisory contains an appendix listing states that mandate reporting of elder abuse when a financial institution holds a transaction or delays a disbursement and also states mandating financial institutions report elder abuse.
John Zasada, JD, CAMS – Regulatory Consulting Director, Financial Institutions Group. John can be reached at email@example.com.
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