When an investment adviser firm suspects a vulnerable or senior client is being exploited financially by a third-party, one of the biggest challenges for the chief compliance officer (“CCO”) is knowing where exactly to report such suspicions of abuse.
The North Carolina Secretary of State’s Security Division is piloting a new program to improve the process for reporting elder abuse. Under this pilot program, when broker-dealers (and hopefully investment advisers) report concerns about financial exploitation of elderly client, these elder abuse concerns will be automatically routed by the platform to the right agency (state securities regulator, adult protective services or local law enforcement) for investigation and resolution. Click here for more details.
Kudos to the North Carolina Securities Division. This pilot appears promising by offering a way to streamline the reporting of elder abuse.
RIA Compliance Consultants has prepared the “Senior/Vulnerable Clients – Compliance Package” to help investment adviser firms with internal and external reporting and documentation procedures when an investment adviser firm suspects financial exploitation or abuse of a senior or vulnerable client by a third party. The documents included in the package are listed below. To see a description of the document, click on the title and follow the link.
- Senior/Vulnerable Clients – Training (PowerPoint)
- Senior/Vulnerable Clients – Training Quiz
- WSP/CoE Section Update – Protecting Older and Vulnerable Clients with Diminished Capacity
- Senior/Vulnerable Clients – Client Authorization to Communicate with Trusted Emergency Contact
- Senior/Vulnerable Clients – State Reporting Requirements
- Senior/Vulnerable Clients – Internal Reporting Form for Exploitation