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Five federal financial regulatory agencies including the NCUA and CFPB, along with the Financial Crimes Enforcement Network (FinCEN) and state financial regulators issued a joint statement Wednesday outlining eight ways credit unions and other financial institutions can help prevent and mitigate financial exploitation of their older members and customers.
FinCEN, state financial regulators and the issuing agencies – which also included the Board of Governors of the Federal Reserve System (FRB), FDIC and Office of the Comptroller of the Currency – emphasized that their statement was not intended to establish new regulatory requirements or supervisory expectations, but to raise awareness and provide strategies to supervised institutions for combating elder financial exploitation, consistent with applicable legal requirements.
According to a June 2023 AARP study, annual losses from U.S. older adults as a result of elder financial exploitation is estimated at $28.3 billion. What’s more, as reported in the interagency statement, the U.S. Department of the Treasury’s 2024 National Money Laundering Risk Assessment described elder financial exploitation as a growing money laundering threat, which has been linked to more than $3 billion in reported financial losses annually, and a FinCEN review of Bank Secrecy Act (BSA) report data found that financial institutions filed 155,415 reports related to elder financial exploitation between June 15, 2022 and June 15, 2023, which were associated with more than $27 billion in reported suspicious activity.
“Older adults who experience financial exploitation can lose their life savings and financial security and face other harm,” the issuing entities said in a press release. “Banks, credit unions and other supervised institutions play an important role in combatting elder financial exploitation and supporting their customers who experience these crimes.”
The statement recommended the following best practices to financial institutions:
- Developing effective governance and oversight, including policies and practices to protect account holders and the institution;
- Training employees on recognizing and responding to elder financial exploitation;
- Using transaction holds and disbursement delays, as appropriate, and consistent with applicable law;
- Establishing a trusted contact designation process for account holders;
- Filing suspicious activity reports to FinCEN in a timely manner;
- Reporting suspected elder financial exploitation to law enforcement, Adult Protective Services and other appropriate entities;
- Providing financial records to appropriate authorities where consistent with applicable law;
- Engaging with elder fraud prevention and response networks; and
- Increasing awareness through consumer outreach.
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