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Elder fraud prevention and response network stakeholders

The right stakeholders form the foundation of a successful network. Explore the types of stakeholders you can invite to your convening and build a list of elder financial exploitation professionals.

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We created a spreadsheet to help you build a core planning team and identify other stakeholders to invite to the convening.

Download stakeholder planning guide

Types of stakeholders to include in your network

Adult Protective Services

Adult Protective Services (APS) investigates reports of abuse, neglect, and financial exploitation. APS social workers assess reported cases to determine the services most appropriate to help eligible victims. These services may include:

  • Home health-aid
  • Resources for food
  • Medical assistance
  • Legal services
  • Utility payment assistance

APS may be managed at the state, county, or local level. The ability of APS to investigate different types of elder abuse, including financial, varies by location and the laws of each state.

Find APS offices in your area

Case review and resolution

  • If an APS investigator believes a crime has been committed, they can cross-report suspected cases of elder abuse, including financial exploitation, to law enforcement for further investigation and prosecution.
  • APS may present cases to a multidisciplinary team (MDT) of experts sometimes known as a Financial Abuse Specialist Team (FAST) or other confidential case review team.

Community education and outreach

  • APS social workers can educate community members on how to recognize and report elder financial exploitation
  • Some APS agencies offer training for law enforcement and financial institution personnel
  • At community events, APS can clarify the agency’s mission to support the safety and independence of older people

Legal action

Some APS agencies can help elderly victims stop financial exploitation by:

  • Helping victims contact family members who can help the older person remain safe and independent, and finding a responsible person or agency to manage the victim's money
  • Helping older adults close or remove signers from financial accounts at risk of exploitation
  • Referring older adults to resources, such as legal assistance to revoke Powers of Attorney, evict an abuser from their home, or file protective orders
  • Referring older adults to conservatorship resources

Local or regional protocols and response

APS representatives can help the network develop regional protocols for prevention of and response to elder financial exploitation.

Cross-training

APS representatives can train network members on:

  • How to recognize elder financial exploitation, providing case examples
  • APS protocol for reporting
  • APS abilities and limitations

APS staff may face multiple challenges to contributing to the network, such as:

  • Being unable to attend all network meetings or respond immediately to requests
  • Being overwhelmed with high volume of cases and limited resources or training on elder financial exploitation
  • Having challenges concerning client confidentiality and collaboration on case review teams with interdisciplinary stakeholders

Additionally, victims of abuse reported to or identified by APS may:

  • Be ineligible for services due to service disqualification guidelines in state laws
  • Refuse to provide consent to receive services
  • Refuse services due to fear of dependence, abuser retaliation, or other retaliation
  • Field supervisors
  • Managing social workers
  • Program managers
  • Regional program administrators
  • Training coordinators
  • Victim services supervisors
  • Deputy Public Guardians/Conservators

Law enforcement

Federal, state and local law enforcement agencies can locate, investigate, arrest, and charge suspected perpetrators who violate elder abuse or elder financial exploitation laws. Agencies handle cases by area, location, or case type, and some agencies provide specially trained personnel for elder abuse cases.

Additionally, Triads of the National Sheriff’s Association are partnerships among law enforcement, community groups, and older adults created to raise awareness of elder abuse crimes. They are frequently led by sheriff’s offices.

Find your state and local law enforcement offices

Search for a Triad near you

Law enforcement can educate community members on:

  • Recognizing the signs of elder abuse in friends and family members
  • Avoiding and reporting suspected abuse, fraud, identity theft, scams and other forms of exploitation
  • Finding resources, such as adult protective services, legal services, or consumer advocacy

Policy development

Law enforcement can influence public policy by holding board member or advisory positions in community organizations.

Law enforcement can face multiple challenges to contributing to the network, such as:

  • The classification of elder fraud as a civil rather than criminal matter
  • The reluctance of victims to cooperate with investigators or report exploiters who they know or may depend on
  • A lack of support from agency leadership for pursuing investigations for prosecution
  • A low percentage of full-time officers available and few resources at small agencies
  • Patrol officers (if higher-ranking office is not available)
  • Elder Service Officers (if available)
  • Financial crime investigators/detectives
  • Crime prevention officers
  • Senior services departments
  • State or local victim assistance offices
  • Deputies
  • Elected sheriffs or police chiefs
  • United States Postal Inspectors

Prosecutors

Prosecutors file criminal charges, present cases in criminal court, and pursue restitution and other legal remedies for crime victims.

Learn how to partner with a prosecutor

State Attorney General’s Office

The state attorney general’s office is responsible for the implementation of the Elder Justice Act and for prosecuting, or assisting in the prosecution of, elder abuse cases. They also conduct public outreach and awareness activities relating to elder abuse.

Federal elder justice coordinators (U.S. Attorney’s Office)

The U.S. Attorney’s Office in each federal judicial district has a designated attorney to serve as the elder justice coordinator. This person:

  • Serves as the legal counsel for the federal judicial district on matters related to elder abuse
  • Prosecutes, or assists in the prosecution of, elder abuse cases
  • Conducts public outreach and awareness activities relating to elder abuse
  • Has access to Bank Secrecy ACT (BSA) information and data from Suspicious Activity Reports (SARs)

District (or State’s) Attorneys

In the United States, a district (or state’s) attorney is the chief prosecutor for a local government area, typically a county. The name of the office varies by state. Except in the smallest counties, a district attorney typically leads a staff of prosecutors known as deputy district attorneys.

Cross-training

Prosecutors can:

  • Establish, lead or participate in a suspicious activity report (SAR) review team for SARs filed on elder financial exploitation
  • Lead or serve as key members of a multidisciplinary case review team
  • Provide legal expertise to law enforcement and Adult Protective Services staff to develop cases for prosecutorial review
  • Inform network members about recent elder fraud cases and any important outcomes or trends

Local or regional protocols and response

In cases of elder financial exploitation, prosecutors can help develop regional protocols for:

  • Sharing information
  • Cross-reporting and interagency referral
  • Gathering evidence including BSA Suspicious Activity Report data and referenced documentation
  • Obtaining and preserving victim and witness interviews and testimony

Prosecutors may have issues contributing to network needs due to multiple factors:

  • Some prosecutors may classify elder financial exploitation as a civil matter rather than criminal
  • Prosecutors may need to maintain confidentiality in case consultations
  • Prosecutors may have limited resources to dedicate to elder fraud and exploitation

Additionally, victims of abuse may be reluctant to cooperate in the prosecution of family due to the relationship or fear of retaliation.

  • State Attorney General’s Office
  • U.S. Attorney’s Office, Elder Justice Coordinator
  • District Attorney or Deputy District Attorneys
  • City or County Attorney
  • Financial crimes prosecutors
  • Fraud/cybercrime prosecutors
  • Consumer fraud prosecutors
  • Elder abuse prosecutors

Nonprofit legal service providers offer free or low-cost legal advice and services to targets and victims of elder financial exploitation. There are programs throughout the country that provide legal services specifically for older adults.

These legal services include:

  • Revoking a power of attorney
  • Filing a temporary restraining order
  • Making or revising a will or trust
  • Evicting an unwanted person from a home

Most legal service providers operate on a county or state level and usually have elder law programs or staff members dedicated to serving older adults.

Community education and outreach

Legal service providers can give presentations on elder financial exploitation regarding:

  • Abuse by a person with fiduciary authority
  • Matters involving real estate and estate planning, such as wills and trusts, or advance directives

Case review and resolution

Legal service providers are experts who can provide legal consultation to a case review team. Conversely, legal services may bring their own cases to a case review team for consultation.

Legal action

Legal service agencies may have access to attorneys on their board of directors or in the community who will contribute short term legal services on a low-cost or pro bono basis.

Policy development

Some legal service providers can help guide the network’s advocacy efforts. Make sure to check if they're prohibited from legislative or policy advocacy as a condition of their funding.

Legal service providers may be affected by multiple issues that prevent them from contributing to the network:

  • Staffing limitations and funding may affect agency ability to accept cases referred by the network
  • Funding restrictions may affect complexity of cases they can take
  • Providers may be prohibited from legislative or policy advocacy as a condition of their funding

Additionally, legal service providers may not be able to represent clients who:

  • Are outside of their service area
  • Are unable to provide documentation
  • Are incoherent and do not have an appointed guardian or other legal representative
  • Victims of Crime Act (VOCA) attorneys
  • Elder law attorneys
  • Legal aid attorneys
  • Will/Trust/Estate attorneys
  • Guardianship attorneys
  • Policy directors
  • Outreach coordinators

Financial institutions and financial service providers

Financial institutions and others that provide financial services have regular in-person interactions with older adults. Their employees may receive training to identify warning signs of elder financial exploitation.

Financial institutions and financial service providers may monitor customer activity to detect suspicious transactions and changes in patterns of financial behavior that may point to financial exploitation.

Case review and resolution

To assist with cases of elder abuse identified by the network, financial institutions and financial service providers can:

  • Review financial documents
  • Identify documents to request in a subpoena
  • Recommend law enforcement obtain SARs and any supporting documentation (Link to Joint Memo)
  • Investigate suspicious transactions and report to law enforcement or adult protective services

Community education and outreach

Financial institutions and financial service providers can:

  • Communicate directly with older customers and educate staff about elder financial exploitation
  • Sponsor, host, or speak at community events and conferences
  • Share information with law enforcement about Bank Secrecy Act requirements, procedures, and confidentiality regulations for filing and handling suspicious activity reports (SARs) on suspected elder financial exploitation (Link to joint memo, and Interagency Guidance on GLBA.)

Legal action

Financial institutions and financial service providers can, and in some states are mandated to, file a report with Adult Protective Services (APS) or law enforcement if they suspect elder financial exploitation.

Financial institutions and financial service providers subject to the Bank Secrecy Act are required by law to file SARs under certain circumstances and can work confidentially with law enforcement agencies to provide detailed information concerning the suspicious account activity and share any supporting documentation referenced in the SAR with law enforcement.

Local or regional protocols and response

Financial institutions and financial service providers, law enforcement, emergency medical first responders, and senior service providers can work together to:

  • Develop regional plans for elder abuse prevention activities
  • Develop protocols for responding to reports of elder abuse
  • Train each other on laws and policies affecting financial institutions
  • Develop internal policies and train staff on the new protocols

Cross-training

Financial institutions and financial service providers can advise other network members on the trends and common types of suspicious transactions.

Learn more about cross-training

Financial institutions and financial service providers must abide by laws regarding disclosure of customer information to third parties. They may have restrictions on:

  • When they are legally allowed to share information about an older or vulnerable account holder
  • Who they can information share with
  • How much they can share

Financial institutions

  • Depository Institutions (banks, credit unions)
  • Money services businesses (MSBs)
  • Investment banks
  • Insurance companies
  • Loan companies

Financial service providers

  • Accountants (CPAs) and forensic accountants
  • Financial planners and advisors
  • Mortgage brokers
  • Investment advisors
  • Real estate professionals
  • Insurance agents

Staff contact types

  • Bank Secrecy Act / Anti-Money compliance officers
  • Community Reinvestment Act (CRA) compliance officers
  • Data security loss prevention personnel/supervisors
  • Fraud investigation supervisors
  • Government affairs personnel
  • Training officers
  • Marketing directors
  • Foundation leadership

Professional associations

Professional associations, such as state banking associations, credit union leagues, or payment associations, may assign staff from these groups:

  • Executive leadership
  • Member relations
  • Government affairs
  • Training officers
  • Marketing and events managers
  • Foundation leadership

Aging and Disability Resource Centers and Area Agencies on Aging

These organizations provide a variety of services to help older adults live independently and reduce the risk of financial exploitation.

Aging and Disability Resource Centers and Area Agencies on Aging are often eligible to receive federal, state, local or private funding to provide these services.

Find AAAs and ADRCs in your community

ADRCs connect older adults, people with disabilities, and caregivers to the Long-term Services and Supports (LTSS) system regardless of income.

Services may include:

  • Home health aide
  • Financial assistance for family caregivers
  • Nursing facility care
  • Adult daycare
  • Medication management
  • Housekeeping
  • Transportation
  • Personal care services

An AAA is a public or private non-profit agency designated by the state to address the needs and concerns of older adults. Some AAAs have authority to investigate reports of elder abuse, neglect, and exploitation.

Services may include:

  • Information and referrals to community resources
  • Free and unbiased Medicare counseling
  • Assistance applying for public benefits such as SNAP or Medicaid
  • Educational programs (chronic disease self-management courses, assistance for older victims of crime, etc.)

Elder financial exploitation programs include:

  • Elder rights
  • Elder law
  • Healthy living or case management

Community education and outreach

ADRCs and AAAs can:

  • Offer information on demographics, income levels, and cultural backgrounds of older adults living in the community
  • Identify key neighborhoods and senior living communities to promote network projects and community education
  • Connect the network with partner organizations and service providers throughout the community

Cross-training

These organizations can train network members on resources available to older adults and caregivers.

Learn more about cross-training

Staff at ADRCs and AAAs can face multiple challenges to contributing to a network, such as limited resources to help older victims of abuse and exploitation. Due to limited resources, there may be waiting lists for services.

  • Elder rights directors
  • Senior law project directors
  • Elder crime intervention specialists
  • Elder services directors
  • Community education coordinators
  • Outreach coordinators
  • Capacity-building directors
  • Information and referral coordinators

Financial regulators

Financial regulatory agencies establish and enforce laws and other rules that apply to financial products, institutions, and individual providers on a state or federal level.

Financial regulatory agencies may:

  • Investigate reports of wrongdoing, including fraud, identity theft, scams, and exploitation
  • Revoke or restrict professional licenses or registrations of financial service providers
  • Fine companies or individuals violating the law
  • Have access to SARs filed with the US Treasury
  • Encourage financial institutions to engage in activities to protect older account holders from financial exploitation

Inviting financial regulators to your meetings can also encourage the engagement of financial service providers.

Case review and resolution

Financial regulators can:

  • Refer cases to law enforcement for criminal prosecution
  • Encourage financial institutions and others to train staff to recognize and report elder financial exploitation pursuant to federal or state laws
  • Share trends with other stakeholders to inform decision-making

Community education and outreach

Regulatory staff:

  • Can introduce network leadership to representatives from other state or national agencies
  • Can invite network leadership to attend local, regional, or national conferences and events
  • May conduct training on the Money Smart for Older Adults and other community education programs

Cross-training

Financial regulators can:

  • Train network members on the regulatory agency’s role in fighting elder financial exploitation
  • Offer consumer resources and educational programs on elder fraud
  • Share information about their work and resources at network and stakeholder events

Learn more about cross-training

Regulators may not have the staffing to attend regular meetings or may not have a local presence.

State level

  • State banking regulators
  • State credit union regulators
  • State securities regulators
  • State consumer protection offices
  • Contractor state licensing boards (home improvement or construction fraud)
  • State insurance regulators

Federal level

  • Department of the Treasury, Financial Crimes Enforcement Network (FinCEN)
  • National Credit Union Administration (NCUA)
  • Federal Reserve
  • Office of the Comptroller of Currency (OCC)
  • Consumer Financial Protection Bureau (CFPB)
  • Securities and Exchange Commission (SEC)
  • Commodity Futures Trading Commission (CFTC)

Self-regulatory

  • Financial Industry Regulatory Authority (FINRA)
  • National Futures Association (NFA)