On July 17, 2019, the CFPB issued an updated advisory to financial institutions encouraging them to work with law enforcement agencies “whenever they suspect that an older adult is the target or victim of financial exploitation.” In their advisory, the CFPB also recommended that financial institutions file SARs - which FinCEN has already provided guidance on.
The 25 page advisory provides a number of recommendations for preventing and responding to elder financial exploitation. Included in the appendices of the advisory are a number of state specific requirements, which would be beneficial to those financial institutions who may experience elder financial exploitation in multiple states.
The full advisory can be found here.
