Free NWCUA Video Fulfills Vulnerable Adult Training Requirement

In last year’s legislative session Substitute Senate Bill 6202 was passed, which requires credit unions operating in Washington state to train their member facing employees on recognizing vulnerable adult abuse. The NWCUA has produced a free training video designed to meet this requirement, and that video is available for viewing on its website.

All credit unions with operations in Washington State are required to train their member facing employees. This includes federal credit unions and Oregon state chartered credit unions with branches in Washington. The NWCUA has also developed a model acknowledgement form for employees to fill out, available in the Resources section of InfoSight.

But all credit unions, not just those with operations in Washington, need to pay attention to vulnerable adult abuse. Elder abuse can trigger a Suspicious Activity Report or SAR. The Financial Crimes Enforcement Network (FinCEN) released a new advisory to help financial institutions spot and report on activities involving elder financial exploitation. The advisory, Advisory to Financial Institutions on Filing Suspicious Activity Reports Regarding Elder Financial Exploitation , contains red flags, or indicators that abuse may be occurring and specifically asks financial institutions to include the term “Elder Financial Exploitation” on filings of suspicious activity reports (SARs).

FinCEN requests that financial institutions select the appropriate characterization of suspicious activity in the Suspicious Activity Information section of the SAR form and include the term “elder financial exploitation” in the narrative portion of all relevant SARs filed. Explicit mention of a particular term in the SAR greatly assists investigators in quickly identifying possible illicit activity.

The red flags noted in the advisory include both activity that may come to bank personnel attention through monitoring transaction activity and through interactions with customers or their caregivers:

  • Frequent large withdrawals, including daily maximum currency withdrawals from an ATM, debit transactions that are inconsistent for an elder, or sudden non-sufficient fund activity;
  • A caregiver or other individual shows excessive interest in the elder’s finances or assets, does not allow the elder to speak for himself or herself, or is reluctant to leave the elder’s side during conversations.

The advisory contains a more complete listing of various indicators of elder financial exploitation.

This reporting is meant to complement financial institutions’ existing policies and procedures on reporting suspected elder financial exploitation to local and state authorities, to aid in the detection and deterrence by appropriate government authorities of criminal activities.

Posted in Compliance, Events, NWCUA.