The CFPB recently issued an Advisory regarding elder financial exploitation titled “Advisory for financial institutions on preventing and responding to elder financial exploitation”. This is an area credit unions often struggle with. Is what you are seeing really exploitation? Should you contact someone? Does it violate privacy laws to speak to someone about the issue? It is an area where we are in a perfect position to help out a member and we do want to help, but we aren’t always sure how to go about it. So, any guidance about how to approach this tricky issue is welcome news.
First, the CFPB advisory isn’t an interpretation of a law or a rule and is not binding on financial institutions. However, is does contain valuable benchmarks and best practices to help credit unions identify and respond to elder financial exploitation. And the recommendations in the advisory are very common sense ideas. Let’s go through them at a high level:
- Develop procedures to address this issue that include training and creation of member consent for information sharing with trusted third-parties.
- Provide training for management and staff to prevent, detect and respond to elder financial exploitation.
- Use technology such as reports and transaction monitoring software to identify unusual account activity.
- Report suspected exploitation to appropriate local, state, and/or federal authorities.