Financial institutions in Washington can refuse to disperse funds when they suspect financial exploitation of a vulnerable adult is being attempted, may have occurred, or may have been attempted. Financial institutions are not required to place a hold and may use discretion to determine whether to do so. If a financial institution decides to place a hold, it must make a report to adult protective services (“APS”) and law enforcement and make reasonable efforts to notify all persons associated with the account. When a securities transaction is involved, the Securities Division would also appreciate being notified. You can notify the Securities Division by filing a complaint or by contacting Kristen Standifer at 360-902-8760. Complaints may be filed online.
In addition, financial institutions located in Washington are required to train employees who have contact with customers and access to account information on a regular basis. For more information, see Washington’s financial exploitation of vulnerable adults statute, RCW 74.34.215 and RCW 74.34.220.
FINRA Panel on Communication Between APS and Professional Reports of Financial Exploitation
FINRA recently released a virtual conference panel on Communication between Adult Protective Services (APS) and Professional Reporters of Financial Exploitation. Panelists include Akiles Ceron, the program director of the San Francisco APS; Kyle Innes, the Associate Director of State Government Affairs at FINRA; Debbie Noury, the senior director of the Elder Financial Investigations team at Fidelity Investments; and a licensing and examination supervisor for DFI’s Securities Division, Kristen Standifer. The panelists explore the evolving regulatory structure surrounding senior investor protections and the challenges facing financial services professionals when developing an effective, efficient, and integrated protection framework.
The topics discussed include how APS operates, the nuances of reporting, how firms monitor for financial exploitation, training programs, the challenges of communication between APS and firms, and the advantages of reporting to state securities regulators even when not required to do so.