As the holiday season quickly approaches, thieves may also be looking for a way to finance their holiday spending. Financial fraud is an ever present problem and seniors account for almost 30% of all fraud victims.
Employees are often hesitant to report suspected abuse because they do not want to infringe on the member’s privacy and subject themselves and/or the credit union to legal action. The NCUA recently issued a Letter to Credit Unions (Letter No.: 13-CU-08) with guidance clarifying that action can be taken if you believe an account holder may be a victim of elder abuse or financial exploitation.
The NCUA, along with other federal regulatory agencies clarified that “you can report suspected abuse to law enforcement, social services, and other local state or federal agencies without violating the privacy provisions of the Gramm-Leach-Bliley Act.”[i]
What is elder abuse? It involves the illegal or improper use of an older adult’s funds, property, or assets. Elder abuse can often be at the hands of the people you least expect – family members, caregivers, financial advisors, or handymen. Credit union employees are often in a better position than others to identify elder abuse; they see the large or unusual transactions, they know what a members normal account activity looks like, and can be familiar with the members behavior.
Are your employees trained to spot signs of elder abuse? Would they know how to react or what to do if they did identify signs of abuse?
The Consumer Financial Protection Bureau (CFPB) and the Federal Deposit Insurance Corporation (FDIC) have developed an instructor-led training and awareness tool called Money Smart for Older Adults. This training provides education on the common types of elder financial exploitation, scams targeting veterans, identity theft, medical identity theft, scams that target homeowners, planning for unexpected life events, and how to be financially prepared for disasters. The CFPB provides a Participant/Resource Guide for participants to utilize during these lessons.
So, does your credit union have a policy and procedure in place to ensure employees file a report when they suspect elder abuse? If not PolicyWorks may be able to help you create your policy and procedure.
Information and resources to help prevent elder abuse:
MyCreditUnion.gov – Pocket Cents
National Center on Elder Abuse (U.S. Department of Health and Human Services)
Elder Abuse – Fraud and Financial Abuse (National Criminal Justice Reference Center – U.S. Department of Justice)
[i] The guidance was developed jointly by NCUA, the Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Trade Commission, Office of the Comptroller of the Currency, and Securities and Exchange Commission.