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Data Spotlight

Suspicious Activity Reports on Elder Financial Exploitation

By the CFPB Office for Older Americans – NOV 15, 2021
Contact the Office for Older Americans: olderamericans@cfpb.gov

Financial institutions file Suspicious Activity Reports (SARs) to report suspected financial crimes to the federal government. Filers can indicate in their SARs whether the suspicious activity involves elder financial exploitation (EFE). Law enforcement can access the SARs and use the information to conduct investigations and potentially stop EFE. In 2020, financial institutions filed over 62,000 EFE SARs involving over $3.4 billion.

Over 62,000 EFE SARs were filed during 2020

In 2020, financial institutions such as banks, credit unions, and money transmitters filed 62,014 SARs involving suspected elder financial exploitation (EFE SARs).1 The total number of EFE SARs filed in 2020 was about 300 fewer than in 2019 (62,298). The relative consistency in the number of EFE SAR filings since 2018 differs from the trends in filings for all types of SARs, and trends in fraud reports submitted to the Federal Trade Commission’s Sentinel database. For example, between 2019 and 2020, general SAR filings grew from approximately 2.3 million to 2.5 million (8.8 percent). According to FTC’s Sentinel data, the number of fraud reports filed by adults age 60 and older with the FTC increased from 319,900 to 334,400 (4.5 percent) between 2019 and 2020.2

Banks and credit unions filed more than half of all EFE SARs in 2020

The numbers and patterns for EFE SAR filings vary significantly by type of financial institution over time. Depository institutions such as banks and credit unions filed nearly 60 percent of all EFE SARs in 2020. While the share of EFE SAR filings by depository institutions has varied over time, the total number of EFE SAR filings by depository institutions has consistently increased from approximately 16,000 in 2014 to 36,500 in 2020. Money services business (MSBs) are historically the second most common type of filer. MSBs’ filings show the largest variations in number and share over time. In 2017, MSBs accounted for nearly 60 percent of all EFE SAR filings, but in 2020 they accounted for only 20 percent of filings. From 2017 to 2020, filings by MSBs declined from approximately 36,300 to 12,400. In 2020, filings by other entities accounted for 21.2 percent of all filings. Filings by these other types of financial institutions have increased consistently from 1,400 in 2014 to 13,200 in 2020.

Figure 2: Number and percentage of EFE SARs filed by filer type (2014 – 2020)

Year Depository Institutions (number) Depository Institutions (percent) Money Services Businesses (number) Money Services Businesses (percent) Other (number) Other (percent)

2014

15,936

73.6%

4,327

20.0%

1,393

6.4%

2015

17,907

70.0%

5,631

22.0%

2,028

7.9%

2016

20,341

38.7%

29,698

56.4%

2,594

4.9%

2017

21,839

34.8%

36,254

57.7%

4,714

7.5%

2018

24,454

45.4%

22,130

41.0%

7,340

13.6%

2019

33,920

54.5%

20,125

32.3%

8,253

13.3%

2020

36,462

58.8%

12,387

20.0%

13,165

21.2%

Source: CFPB analysis of FinCEN’s SAR Stats at https://www.fincen.gov/reports/sar-stats. Note: The “other” filers category includes casinos, broker-dealers, insurance companies, mutual funds, futures commissions merchants and introducing brokers in commodities, loan or finance companies, and housing government-sponsored enterprises.

Financial institutions reported over $3.4 billion in suspicious activities in EFE SARs in 2020

The dollar amounts involved in the suspicious activities reported in EFE SARs include actual losses to the older adult or to the filer, unsuccessful attempts to steal the older adult’s funds, or both. Because SARs report the amount at risk of being lost, or an actual loss to an individual or financial institution, as reported by the financial institutions, some reports may include uncommon amounts, often in the billions of dollars. This could be the result of an attempt to deposit a fake check purportedly worth billions of dollars or attempts to withdraw billions of dollars from a customer’s account. EFE SARs with these large suspicious amounts are uncommon. To examine trends in the total amounts by year, the CFPB excluded the total amounts from the top 1 percent of SARs by year. After this exclusion, the total amount involved in EFE SARs was $3.4 billion in 2020, an increase from $2.6 billion in 2019. This is the largest year-to-year increase since 2013.

Over half of EFE SARs in 2020 involved a money transfer or a checking or savings account

A variety of, and sometimes multiple, financial products and services and payment methods can be involved in a suspicious transaction. In more than half of the EFE SARs filed in 2020, a checking or savings account or a money transfer was involved. Cash (in the form of U.S. currency) was involved in 38 percent of EFE SARs. Checks were involved in 24 percent of EFE SARs. Debit cards and credit cards were involved in 17 percent and 12 percent of EFE SARs, respectively. Despite the millions of stimulus payments and unemployment benefits payments issued to older Americans, in addition to regular Social Security benefits and tax refunds, only 3% of all EFE SARs in 2020 directly reported a government payment.

The number of EFE SARs involving government payments grew in 2020

While government payments were directly involved in a small share of EFE SARs overall, EFE SARs involving a government payment saw a notable increase between 2019 and 2020. The increase was particularly evident after June 2020, when government payments such as stimulus and unemployment benefits payments were issued to millions of older Americans. As a result, EFE SARs involving government payments accounted for a greater share of EFE SARs in 2020 (3 percent) than in 2019 (1 percent).

More information

The CFPB has provided regulatory guidance, voluntary recommendations, and other materials to assist financial institutions with preventing and responding to elder financial exploitation. These resources can be found at consumerfinance.gov/olderamericans.

Endnotes

  1. Other financial institution categories include: casinos, broker-dealers, insurance companies, mutual funds, futures commissions merchants and introducing brokers in commodities, loan or finance companies, and housing government-sponsored enterprises.
  2. Federal Trade Commission, Reported Frauds and Losses by Age, https://public.tableau.com/app/profile/federal.trade.commission/viz/FraudReports/FraudFacts (last visited Sept. 2021).