Webinar: Building Collaboration to Prevent and Address Elder Financial Abuse — consumerfinance.gov


>>>>>>Welcome and thank you for standing
by. At this time all participants are in a listen-only
mode. During todayís Q&A session, if youíd like
to ask a question, please press star then 1. Todayís call is also being recorded. If you have any objections you may disconnect
at this time. Now Iíd like to turn todayís meeting over
to your host, Mr. Luke Reynolds. Thank you. You may begin.>>>>>>Good morning or good afternoon everyone. Thank you for joining. The purpose of our Webinar is to encourage
more financial institutions to develop relationships with law enforcement to address or redress
elder financial abuse. Before we get started, remember that there
are two steps to participate: calling a conference call number, and joining on your computer. If youíre not able to access on the computer,
itís probably because of a firewall issue. You do not need to worry. We sent out the PowerPoint yesterday. You can listen and follow along with the PowerPoint. Again, donít worry if youíre not able to
access the WebEx portion using your computer. If you did not receive the PowerPoint yesterday,
please email us. Any email you have for us works, including
CommunityAffairs at FDIC.gov or my email address. And now to a quick introduction to WebEx. If youíre able to access WebEx, youíll see
on the right panel that thereís a section for Q&A and Chat. If you have any questions during the Webinar,
please type questions in there. Weíre going to select a very few at the end
to answer, assuming we have time. Iíd like to now turn the program to Emerson
Hall. Emerson?>>>>>>Thank you Luke. My name is Emerson Hall. Iím an Acting Associate Director for Community
Affairs at the FDIC. Elder financial abuse is widespread. Itís a serious crime, not just because of
the financial impact, but on the emotional wellbeing and sense of independence of older
adults. As a deposit insurer, FDIC has a unique role
and strategic voice to facilitate the dissemination of objective, quality strategies and resources
that can be adopted throughout the nationís banking system. To that end, our guest speakers will discuss
resources that we trust will help you develop stronger collaboration to prevent and address
elder financial abuse. As you will see from the agenda on Slide 4,
we will start by taking a close look at elder financial exploitation. Then we will hear from an on the ground investigator
who will share her perspective about how banks can be helpful in law enforcement investigations
of elder financial abuse. That will be followed by an introduction of
how recent developments in elder financial justice can benefit local community efforts. What can you do when this Webinar is over? We have a few ideas for you. First you will hear how to get involved in
elder fraud prevention and response networks. Then we will introduce you to a free resource
to help educate those at risk, while encouraging advanced planning. That educational resource is a valuable tool
to promote collaborations between banks, non-profits, law enforcement, social service organizations,
and other key organizations in their communities. We are pleased to join with the CFPB for todayís
Webinar. I am joined here with Stacy Canan, Assistant
Director of the CFPB. Stacy, would you like to say a few words?>>>>>>Sure. Thank you so much Emerson. And thanks to you and your team at the FDIC
for co-hosting todayís Webinar with the Consumer Financial Protection Bureau. Today is another example of our excellent
partnership that we began back in 2012. Iíd like to welcome everyone today and, thank
you very much for joining us. The large number of registrants is wonderful,
and shows how seriously financial institutions and others are taking the problem of elder
financial exploitation. I have the honor of leading the Office for
Older Americans at the CFPB. A top priority of our office since we opened
our doors in 2011 has been to develop strategies and programs, and to conduct research, to
find ways to help prevent and improve responses to elder financial exploitation. Youíre going to hear a lot about a few of
our recent efforts today from our team member, Jenefer Duane, including the update of the
Bureauís 2016 Advisory for Financial Institutions for Preventing and Responding to Elder Fraud. We released the updated advisory on July 17. And you can find it on our Web site – ConsumerFinance.gov. As Emerson mentioned, as financial regulators
we had the unique opportunity to help financial institutions protect their older account holders
from fraudóand the Advisory for Financial Institutions aims to do this by offering an
array of recommendations and best practices. Before I pass the program to Jenefer Duane
to start the presentations, Iíd like to thank our speakers today, Richard Goldberg, Andrea
Higgens, my staff member Jenefer Duane, David Ramos of the FDIC, and a special thanks to
Luke Reynolds of the FDIC, who has been a terrific partner with us in creating and distributing
our recently award-winning, Money Smart for Older Adults Program. Thanks and Iím going to pass it on to Jenefer.>>>>>>>Great. Thank you Stacy and thank you all at the FDIC
for co-hosting with us. And thanks to all of you as well, for taking
the time to join us today. Iím Jenefer Duane. Iím Senior Program Analyst in the Office
for Older Americans at the CFPB. We develop tools and initiatives and resources
for older people who we describe as adults age 62 and older. But we also have a secondary audience which
we consider a primary audience, and those are people age 45 or so plus, who are the
adult family members. Sometimes they are financial caregivers of
older adults, and they also are presumably the next wave of older adults. So we have a broad spectrum of constituents. Our goal to protect older consumers from unfair
abusive and deceptive practices and financial exploitation is a major priority. As Stacy referred to, we had an announcement
last week of an update to our Advisory for Financial Institutions on Preventing and Responding
to Elder Financial Exploitation. The focus of the advisory is on the reporting
of suspected EFE — Elder Financial Exploitation, — by banks and credit unions, depository
institutions primarily, to appropriate local, state, and federal responders. The advisory provides new information on reporting
that is based on federal and state legislative changes, including statutory charts. So, thatís some brand new info. It also highlights findings from our analysis
of suspicious activity reports that have been filed on elder financial exploitation, which
I will highlight in just a moment. But first, I would like to just provide a
brief primer for those of you who are new to elder financial exploitation or EFE. There are many definitions of EFE. We use a very simple one: the illegal or improper
use of an older personís funds, property, or assets. There is a whole range of perpetrators from
offshore scammers to those closest to the other adult such as family members or caregivers. We basically divide these up into persons
known to the older person and strangers. So thereís two categories. Thereís been quite a lot of studies done
in the past few years. Itís increasing, thankfully. But studies are showing that what weíre seeing
is the tip of the iceberg. Only a small fraction of incidents are reported
to authorities. One study showed that only one in 44 cases
was reported to an entity that can provide services to a victim. And the estimates of annual dollars lost varies
widely. Some studies from a few years ago estimate
$2.9 billion annually, to a more recent study of $36 billion. So, letís talk about Suspicious Activity
Reports. Those of you bankers on the phone would be
very familiar with them. But I also know we have an audience of law
enforcement and others who may not be as familiar so, bear with me. The Bank Secrecy Act mandates that financial
institutions report suspicious activity that might indicate criminate activity. And these reports are made to FinCEN, the
Financial Crimes Enforcement Network, which is a bureau within the United States Treasury. So our filers include banks, credit unions,
money service businesses, broker/dealers, securities broker/dealers, and others. Access to these filings, Suspicious Activity
Reports, and knowledge of their existence, is strictly limited to law enforcement and
financial regulators. And law enforcement can use information in
the SARs to trigger investigations and to support ongoing investigations and to identify
subjects. I also want to mention that in 2011, FinCEN
issued an advisory that noted that SARs are valuable avenues for financial institutions
to report. There is a comprehensive list of transactional
red flags signaling EFE. Thereís also behavioral red flags listed
there. So, if you have not seen that you can search
for FinCEN Advisory 2011. We also recently had an update to that advisory
which is a memorandum on financial institution and law enforcement efforts to combat elder
financial exploitation. For those of you what are furiously taking
notes, fear not. We will send out links and tell you where
to go find all of this a little bit later in the program. FinCEN, in 2013, introduced the electronic
SAR Filing Form, which now includes a designated category for elder financial exploitation. This makes it much easier for investigators
to go in and search by topic. Itís a quantum leap forward in terms of reporting
in this country. The EFE SARs provide a clear and complete
and concise description of activities included in the narrative field. And then there are other fields as well. This past year, we released a study of SAR
data. We did a very comprehensive study at the Consumer
Financial Protection Bureau. We analyzed limited structured data from other
financial exploitation SARs dating from April 2013 to December of 2017. That was 185,214 SARs that were filed by all
types of filers, including depository institutions. We took a random sample. We read full SARs transcripts of a representative
sample of over 1,000 SARs. We analyzed numerous data elements that allowed
us to make findings about patterns, issues, and the amounts involved. Throughout the project, we worked very closely
with FinCEN staff. You will find more detailed information about
the methodology of our study in the appendix of the report. But, hereís a few highlights for you. This slide shows the EFE SARs findings quadrupled
from 2013 to 2017, from about 1,300 SARs per month in 2013, to 5,300 per month in 2017. This was much greater than the overall growth
rate for all SARs, which was only 40%. The incidents reported in SARs likely account
for only a tiny fraction of all incidents of other financial exploitation in any given
year. Perhaps, only 2%. In fact, based on one of the lowest estimated
prevalence rates, there were 3.5 million cases of elder financial abuse in 2017. Yet there were only 63,000 SARs filed on elder
financial abuse in 2017. And financial institutions reported a total
of 1.7 billion suspicious activities in the year 2017. And one-third of the individuals who lost
money were age 80 and over. The graph shows the percentage for older adults
by age group. As shown, one-third who lost money were ages
80 and older. Twenty-three percent were 70 to 79. And as you can see here, in 29% of the cases,
the age was unknown, because it was not listed on the SAR. We also examined whether the average loss
varied by age group. Among adults who lost money, adults age 70
to 79 had the highest average loss of approximately $45,000, followed by those age 80 and older
who lost an average of $39,000. The SARs also identified a variety of suspects. Half of the SARs identified a stranger, either
located in the U.S. or internationally, as a suspect. Thirty-six percent identified persons who
were known to the elder. Approximately 14% of all SARs do not provide
enough information to determine the relationship of the suspect to the targeted older adult. Another important finding is the specific
categories of people known to the other adult. As you can see, the largest category are family
members. Twenty-five percent of all EFE SARs involved
family members. Among known suspects, family members are the
largest category. When we look specifically at family members,
we find that the child of the targeted older adults is often the most common suspected
perpetrator. We saw earlier that strangers are involved
in over half the activities reported in SARs. This graph shows a breakdown of the location
of these stranger suspects. And fewer than one-third of the SARs indicated
that the filer reported the suspicious activity to a local, state, or federal authority. Slightly more than half of depository institution
SARs indicated that the depository institution reported. But only 1% of MSB SARs indicated that they
reported to any authorities. We donít know for sure that almost three-quarters
didnít report. But they didnít say that they did, in either
the law enforcement contact field of the SAR or in the narrative portion. If financial institutions that are filers
donít notify first responders, those responders are less likely to have the opportunity to
take action to help the victim and prosecute the perpetrator. We see this as a potential missed opportunity. So the implications and next steps – SARs
indicate that EFE is widespread and damaging. This highlights a need for strong interventions
by financial institutions, law enforcement, social services, and the involvement of policymakers. We found that financial institutions are filing
more EFE SARs. But in most cases the SARs donít indicate
that they are reporting EFE to law enforcement or adult protective services. Again, a potential missed opportunity to strengthen
prevention and response to victims. EFE SARs are definitely a useful, untapped
resource for monitoring and for measuring the incidence of elder financial exploitation. The types of suspects, activities reported
by money service businesses — MSBs and depository institutions — differ significantly. So interventions can be tailored accordingly. And also law enforcement is becoming increasingly
aware of the existence of SARs that are being filed on elder financial exploitation. Remember that this only started in 2013. So awareness on the ground is increasing. And law enforcement through some of the work
thatís going on around the country that youíll hear about in a little bit are learning to
mine the databases of SARs to be more proactive in investigating cases and bringing about
more prosecutions. So with that Iím going to turn the program
over to Andrea Higgens.>>>>>>Great. Thank you so much Jenefer. I appreciate it. Thank you all for joining us today. My name is Andrea Higgens, and Iím a Criminal
Elder Abuse investigator with the San Mateo District Attorneyís Office in Northern California. Iíve been in law enforcement for almost 20
years, the last seven of which I spent working on elder abuse issues throughout the country. But specifically in my little county in Northern
California. Hereís my official disclaimer, which is essentially
that if you have any questions or concerns about what I talk about today, please let
me know. So we talked a little bit during Jeneferís
presentation about SARs. Iím going to drill down a little bit more
specifically into, how law enforcement can use this tremendous resource of Suspicious
Activity Reports. How they can add to criminal investigation,
and how they really create an opportunity for financial institutions to collaboration
with law enforcement. So, what is a SAR? The Bank Secrecy Act mandates that financial
institutions report certain categories of suspicious transactions that might indicate
criminal activities to FinCEN. The reports are called Suspicious Activity
Reports, and they may contain crucial activity like account numbers and the names of other
involved parties as well as, the description of the suspicious activity and, the results
of any investigation into the activity. FinCEN allows sworn law enforcement officers
who are investigating a crime to request SARs related to their suspect, their suspectís
associates, and their suspects businesses. So, why do SARs get filed or, when do SARs
get filed? A financial institution may be required to
file a SAR if it knows, suspects, or has reason to suspect a transaction conducted or attempted
by, at, or through the financial institution involves funds derived from illegal activity
or attempts to disguise funds derived from illegal activity; whether it is designed to
evade regulations promulgated under the Bank Secrecy Act (BSA); whether it lacks a business
or apparent lawful purpose, or whether it involves the use of the financial institution
to facilitate criminal activity. If youíre investigating a financial crime,
these categories are exactly what youíre looking for when it comes to getting background
information on your suspect. So, what do SARs include? Filers include essential facts about the reported
suspicious activity including dates, location, and transaction amount. Further, narratives within the SAR may include
account numbers and references to supporting documentation, as well as information about
individuals suspected to be involved in the suspicious activity. These are all really crucial pieces of information
for us to have on the law enforcement side as weíre looking into our elder financial
exploitation investigation. Now that we know a little bit more about SARs,
what do we do as law enforcement officers once we have the SARs. Each SAR has an accompanying case number and
usually a contact name and number for the SAR filer. Reach out directly to the filer and request
the entire file related to the SAR. SAR files have to be kept for five years. And financial institutions or filers are required
to give you the complete file without a search warrant or other court orders. Most filers are thrilled when you request
a SAR because theyíve been waiting for someone to pay attention to the suspicious activity. The SAR file, not the SAR itself, is really
the basis for your continued investigation as a law enforcement officer. It will have far more information than the
SAR itself. And it may detail investigative steps the
filer has already taken, which may save you significant work and refine your investigation. So truly the SAR is a pointer. It simply points you in the direction of the
SAR file. The SAR file is the destination and the source
of the information for your investigation. What can SAR files add to your criminal case? They can help you confirm your suspect has
engaged in suspicious financial activity in the past. They can show a pattern of criminal behavior
your prosecutor may be able to use against the suspect, even if those actions arenít
charged. They can help identify other potential victims
of current or previous fraud schemes. They can pinpoint other businesses that you
may not be aware of that your suspect has been connected to. They can help locate potential co-conspirators. And ultimately, they can give you probable
cause for search warrants and subpoenas, which for us on the Criminal Investigation side,
are really the foundation that we build most of our elder financial abuse cases on. Sometimes they can also show you other financial
accounts that you werenít aware of that your suspect has access to. You may be able to include those accounts
in your search warrant. Or you may be able to freeze the assets in
those accounts before your victimís money is exhausted. So, almost more importantly, what do we not
do with SAR information? Access to SARs and their use is restricted
under federal law. Knowledge concerning the existence of a SAR
is strictly confidential and is generally limited to law enforcement and financial regulatory
agencies. So, do not refer to the existence of SARs
in police reports or search warrant affidavits or any other written documentation. We need to treat our SARs like confidential
informant information. We use it as a directional tool. We do not use it as a source for further investigation. We do not share SARs or even their existence
with our non-sworn investigative partners. We are able to discuss SARs with our prosecutors,
but not in a formal and discoverable way. When you receive SARs from FinCEN, FinCEN
sends you a Disclaimer Letter explaining all of the dos and doníts for using information
from SARs. The next three slides contain the specific
language from the FinCEN Disclaimer Letter. Itís very dense information. So just to highlight the key points, law enforcement
personnel may use the information reported on a SAR in connection with any official investigation
or law enforcement function. However, there may be no disclosure of the
fact that a SAR exists, or that a SAR has been filed, to any person outside of the law
enforcement agency. Now I know this sounds a little bit confusing
in terms of then if we have this information but weíre not supposed to use it, how do
we use it? Trust me, Iíll go through that later on in
the presentation. I just want to give you the specifics of the
disclosure requirements upfront, so we have those in mind as weíre looking at SARs down
the road. Disclosure of the subject of the SAR to third
party agencies, i.e., non-sworn law enforcement folks, or to persons who seek information
as part of the discovery request for subpoenas, are generally prohibited. Therefore, law enforcement personnel that
use SAR information as part of their investigative efforts may not confront an account holder
or customer of a filer with a SAR, or include a SAR as an attachment to an affidavit or
other legal documents. Additionally, law enforcement personnel may,
without prior authorization, disclose a SAR to other law enforcement personnel or prosecutors
working on the same or a related investigation, or who may be able to provide assistance in
the matter under investigation. So in summary, we do not disclose SARs or
even the existence of SARs to folks outside of law enforcement or prosecution. And specifically, outside of our individual
investigations team. We do not confront our suspect with the existence
of SARs. And we do not disclose SARs to our victims,
even if our victims were the folks involved in the SARs to begin with. So, Iíve talked a lot about what we donít
do with SARs. So, how do we use SARs on the law enforcement
side? The best practice is to base any investigative
actions on the facts from the SAR file that you receive from the financial institution
or filer. Again, we do not base any investigation action
on the SAR, because the SAR or the existence of a SAR is confidential. So for example, once you have the SAR file
and youíve reviewed it, when youíre documenting in your police report or writing your search
warrant affidavit, it would look something like this. ìOn this date and time I received information
from Jane Smith at Bank of the Bank, indicating that my suspect conducted suspicious banking
transaction on date, related to account number XYZ. Based on this information, I believe X number
of crimes occurred. Or I request that the court allow this financial
institution to release the related records to me.î So we use the SAR file for our basis of information. Not the SAR. We use the SAR as a pointer. As an investigative tool. But we do not use the SAR as a source for
our investigative action. So, how do we get SARs or Bank Secrecy Act
data? First, contact your FinCEN agency coordinator
if you have one. If you donít, or if you donít know, then
use the email address thatís listed above. Or you can contact the Elder Justice Coordinator
in your U.S. Attorneyís Office. The form thatís on the right side of the
slide is the one that you will fill out in order to request SARs from the folks at FinCEN. So switching gears for just a moment, I wanted
to take a moment to talk about why itís so important that our financial services partners
report suspected elder financial exploitation to law enforcement directly and immediately. First, reporting solely to APS can create
an unnecessary delay in the case being investigated, and may result in a case not coming to law
enforcementís attention at all. It can take significant time for APS social
workers to review reports of abuse, contact the older adult, determine if thereís merit
to the allegation, and then determine if the case is potentially criminal. Also, not all social workers may have had
training on applicable criminal laws related to EFE cases. So they may not always be referring cases
to law enforcement that should actually be reported. Additionally, the delay in reporting to law
enforcement can have significant negative effects on our victims. For example, the delay can allow additional
victimization, financial or otherwise. Seventy percent of elders experiencing elder
financial exploitation are being abused in other ways. Also, once the suspect knows that thereís
an investigation, for example, if APS has already made contact, they will take steps
to hide or spend the money. And they may escalate the other existing abuse. The delayed reporting may also prevent timely
assessment of a victimís cognition. Capacity to consent to financial decisions
is often the key to our criminal cases. So we need the opportunity to assess the older
adult as close in time to the crime as possible. These cases are complex and time consuming
for law enforcement. They can take months and even years to complete. And honestly, we need all the time that we
can get. And the reality of it is that many of our
victims can pass away before our cases are prosecuted if thereís a significant delay
in reporting. So really, the best practice is for financial
institutions to report suspected elder financial exploitation to both APS and law enforcement,
simultaneously. This allows the agencies to potentially co-investigate,
which provides a better outcome for the victim who is typically their customer, and also
for the criminal prosecution. Thank you all so very much for your time today
and for your continuing commitment to work collaboratively to protect older adults. Now I will hand it off to Richard Goldberg
from the Department of Justice.>>>>>>Hi (Andrea). Thanks so much. Really appreciate the useful information you
provided to everybody. This is Rich Goldberg, a Senior Counsel for
Complex Litigation with the U.S. Department of Justice Consumer Protection Branch. The Consumer Protection Branch does a variety
of different kinds of criminal cases, all in the consumer protection space. The upshot of my presentation is twofold. For the financial institutions on the line
that are charged with the responsibility of investigating and filing Suspicious Activity
Reports, know that your efforts are not in vain. You are not sending those Suspicious Activity
Reports into a black hole. Law enforcement is using them. In elder financial exploitation space, they
are being used extensively by federal, state, and local officials. Iíll be able to talk in detail about the
federal law enforcements use of those Suspicious Activity Reports. The second point is, for the law enforcement
audience on the line, if you are not using Suspicious Activity Reports, then you are
missing out on some of the most vital intelligence in the elder financial exploitation space. I would encourage you to review reports on
a periodic basis, if not a frequent basis. So set up, especially if youíre in a specific
geographic territory, a scheduled search so that you receive on an ongoing basis, new
reports of SARs that come in, in your territory. Because it is, as Andrea said, critical that
we receive these in a timely way so we can actually do something about both the perpetrators
and the victims, to stop ongoing victimization. So Iíll talk first about the Elder Abuse
Prevention and Prosecution Act, or EPA. Donít worry, Iím not going to go into a
lot of legal detail. Basically EPA is a law that was enacted in
2017 to encourage and assist in the prosecution of elder justice matters in the Department
of Justice and its law enforcement agencies. In part, the EPA requires that the Department
create a position, a National Elder Justice Coordinator position, which was filled right
away by Toni Bacon. And she has done a phenomenal job of leading
at the highest level, the Departmentís efforts in the elder justice area. It also requires a report to Congress on a
yearly basis, of all the Departmentís efforts in the elder justice space. There was a report last fall, and it outlined
many of the efforts that the Department is engaging in. One of the other key components of EPA was
that it required that for every federal district across the country, that the U.S. Attorneyís
Office filled a position of an Elder Justice Coordinator. And there are likely a number of Elder Justice
Coordinators who are on the line. And I can speak from experience that this
group of Assistant U.S. Attorneys across the country is enthusiastic and eager to work
with financial institutions to learn of crimes occurring that are victimizing, whether fraud
or physical abuse, or other kinds of elder justice issues, against members of the community. And theyíre also interested in outreach to
financial institutions, to non-governmental organizations, and potential victims to get
the word out on the types of schemes that are prevalent and victimizing individuals
in their territory. So I would encourage folks to feel free to
get in touch with your Elder Justice Coordinator. You can reach out to your U.S. Attorneyís
Office, and they should be able to identify who is the Elder Justice Coordinator in your
area. The roles of the Elder Justice Coordinator,
as I laid out, are coordinating federal and state professionals, receiving extensive training,
and increasing the number of federal prosecutions of these sorts of crimes. The goal of these efforts is to increase the
cooperation between the Department and entire community to ensure that the older American
community is protected. Slide 43 has the specific language of the
law, which you can read at your leisure as to what the Elder Justice Coordinator responsibilities
are. The Department is engaged in a number of ongoing
enforcement actions, both in the civil and the criminal context, against elder financial
exploitation. Slide 45 outlines some of the inter-agency
enforcement actions in which we are engaged. So for example, in May of 2016, there was
a large-scale action to shut down mass mailing fraud schemes across the country. And indeed, around the world. Because youíll see a theme in what Iím describing. A lot of the efforts are geared towards the
transnational criminal organizations that are seeking to victimize elderly Americans. There obviously are a number of actions that
are being taken across the country at all levels – federal, state, and local – against
the relatives, friends, children, financial advisors on a local level who are taking advantage
of older Americans. Now a lot of the nationwide efforts that are
being spearheaded by the Consumer Protection Branch where I sit, are the efforts against
transnational organizations that are committing criminal fraud against older Americans. So all of the actions on this page speaks
to those. So again, the May 2016 mass mail fraud. In February of 2018, there was a large-scale
elder fraud sweep. In November of 2018 there was a money mule
initiative. And in March of 2019 there was an elder fraud
sweep, which Iíll talk about in a moment. And then we also have elder justice cases
that are coming out on a frequent basis. And you look to the press releases to talk
about those. So why donít I turn back for a moment to
the money mule initiative from November 2018. This may be of particular importance to the
financial institutions on the line. My guess is many of you have seen money mules
who are receiving the proceeds of elder financial exploitation. These are often domestic individuals who are
responsible for receiving the money spent by elderly victims. They receive it and then send it on to the
foreign perpetrator either directly or indirectly. Those money mule SARs are very important to
us. They help us to identify these domestic actors,
which are easier for us to reach than some of the foreign based perpetrators. So those are very important. And to designate those as money mule accounts
are very helpful for us, so that we can search and find those, identify them, and then help
to get them shut down. We are committed to finding foreign-based
fraudsters who are engaging in these schemes, and will investigate and prosecute them very
vigorously. But also getting information about the domestic
actors that are helping to facilitate these schemes is very important. So we encourage you to keep filing those SARs
designating money mules. Iíll talk for a moment about the March 2019
elder fraud sweep. It involved criminal and civil cases by federal
and state authorities. Over 260 defendants were the subject of civil
or criminal cases. Those cases involved over $750 million in
victim losses; over two million U.S. victims. We also engaged in a Consumer Education Campaign. And as part of the elder fraud sweep, we announced
that actions have been taken with respect to over 600 money mules. And again, a lot of those actions are based
on intelligence we get from those who are on this Webinar and others filling out Suspicious
Activity Reports across the country. So keep them coming, where you have individuals
who you suspect are engaging as money mules in elder financial exploitation schemes. Slide 47 is a map of the United States that
shows the U.S. Attorney Officesí that were engaged in either bringing filed cases or
that were engaged in consumer education efforts. And itís really a testament to those Elder
Justice Coordinators on line, and others out there that every single U.S. Attorneyís Office
had an Elder Justice Coordinator who either brought, was responsible for helping bring
cases, or was involved in consumer education efforts. So it was a huge amount of work done across
the country. I outlined the Transnational Elder Fraud Strike
Force. The new Strike Force, announced in June of
2019 is charged with the responsibility of taking down the transnational criminal organizations
— the TCOs — that are engaged in the largest elder financial fraud schemes. There are six Strike Force districts. Those are the federal districts that have
been designated as Strike Force districts that are getting special resources and attention
for purposes of bringing these sorts of cases with law enforcement partners. But all federal districts are encouraged,
as part of the Strike Force efforts, to bring cases and engage in consumer education efforts. Slide 49 goes through some of the more common
transnational elder fraud schemes that we are seeing – lottery, sweepstakes, mass mailing,
and tele-fraud cases. In Jamaica there are a lot of Jamaican lottery
fraud schemes. Their victims are money mules. There are government imposter schemes. Social Security Administration imposter schemes
are among the most popular right now. There are also FBI, Department of Homeland
Security and IRS imposter fraud schemes. The trending themes include that the IRS imposter
fraud scheme, which was very popular over a couple of years, is somewhat on the downturn. And the Social Security Administration imposter
fraud scheme is among the most popular trending schemes right now. So you can look out for schemes involving
those – both victims and money mules – and potential perpetrators. The Tech Support fraud scheme, Iím guessing
most of the financial institutions on the line have seen those. We encourage you, for all of these schemes,
file SARs. Try to use common language in the SARs, because
it allows us to search across the entire SAR database for specific language. To the extent that youíre varying the language
to describe these sorts of schemes, itís a little bit harder for us to isolate the
same kinds of schemes over and over again. So this language that weíre using, tech support
fraud, government imposter fraud, is often helpful for us. So very briefly Iíll go through some of the
Departmentís resources that are available to folks. We provide at the Department, through the
Elder Justice initiative, resources for family, friends, and caregivers who may need assistance,
at www.elderjustice.gov. We try, in a graphical way, to identify in
any particular geographic area, the types of resources that are available for older
Americans, family members, and Adult Protective Services
to provide assistance. Slide 52 shows that if you drill down on any
particular geographic territory, then the Web site is geared to provide resources, telephone
numbers, Web sites, email addresses that may be useful in contacting resources that can
help. Slide 53 – again, this is the Web site. It has some helpful information I would encourage
folks to take a look at. Slide 54 is whatís called the Elder Abuse
Resource Roadmap, which is essentially a decision tree that helps victims, family members, or
others such as financial professionals, to weave their way through a decision tree and
ultimately come to the resource that may be most helpful to you in addressing elder financial
exploitation. And the last, Slide 55, shows just an example
of what happens if you drill down on a specific kind of fraud that has happened. It will bring you, for example, if it involves
securities fraud, it will bring you to a page to file a complaint with the SEC. But there are innumerable different roads
that this roadmap will bring you down, depending on the answers that are given to prompts on
the Web site. So again, Rich Goldberg, from the Department
of Justice. Thanks to CFPB and FDIC for hosting the Webinar. And I will pass it on back to Jenefer Duane.>>>>>>Great. Thank you so much. So now is the time for everybody to fasten
your seatbelts, because we are – we have ten minutes left and Iím going to go very quickly
through this information. Letís just briefly, what is the network? These are groups of stakeholders that come
together in communities across the country. They are sustained because they are not a
one-time event or meeting. Theyíre sometimes called multidisciplinary
teams, FAS or Financial Abuse Specialty teams or coalitions. They have all sorts of names but we call them
a network. The efforts are largely voluntary, from the
formation to operation, to the important distinction from mandated multidisciplinary teams or other
sort of agency protocols. We conducted a study that we released in 2016
on Elder Fraud Prevention and Fraud networks. And you can find it at consumerfinance.gov
Elder Protection Network. Hereís a quick snapshot of networks nationwide. As you can see, the green fill-ins are where
there are networks. And there are large areas with no active networks. Only a quarter of the 3,143 counties in the
U.S. have a known Elder Abuse Network. I do say this with a caveat, that there isnít
really a network of networks. And not all of them are necessarily on the
map. But we did a very comprehensive study, and
that was what we found. So, key findings in the study include the
benefit of networks. And this is the idea to encourage you financial
institutions and law enforcement folks out there to find a local or regional network
and join it if you can. Whether you go to every meeting or an occasional
meeting or introduce yourself or, look for an opportunity to collaborate. They need you. We need you. We need all the boots on the ground here. So other benefits of networks: improved response
to cases and increased reporting of cases. And this is both by the public and also through
interagency collaboration and cross referrals that take place. Itís amazing what happens when folks get
in a room and learn what each other do and what they donít do. And why they can or cannot respond to certain
things. It helps to clear up a lot of misunderstandings
and build relationships. And then things work a lot better in our communities. The memberís skills are enhanced significantly
by trainings that take place, to build capacity to address financial exploitation. And the result is improved coordination of
services for victims, including the use of community resources that are already there. Another finding of our study was that the
most common ways that networks fight financial exploitation is through community education
and raising awareness. And also as I mentioned, professional training
– cross-training between the different entities. And then a very common – or the increasingly
common way is through case review, which may not be a sort of public entity or public presentation,
but there may be members of the team who come together to do case review on a specific case-by-case
basis so that they can work together on how best to help the victim, and stop the abuse
or exploitation. The point of this slide is, donít reinvent
the wheel. There are a lot of resources already out there
for you. We will be sending you some links, but there
are resources through the DOJ, through the FTC, through the FDIC, through all of us,
that you can take and apply to your needs, locally. So donít feel that you have to build things
from the bottom up. We, the CFPB Office for Older Americans, started
a program called, the Elder Fraud Prevention and Response Networks Program. And what weíve been doing is convening stakeholders
in areas where there either are no existing networks or, there are networks that would
benefit from some support and enhancement. And to date we have done eight of these convenings. And you can see the states down below where
weíve been. More to come. We just produced a report that looks at those
convenings that we have done and have looked back at what those partners have done, which
has been very, very encouraging. And there has been lots of innovation and
lots of information sharing between them. But the purpose of the report is to share
the learnings and achievements from the convenings, and encourage the establishment of new or
enhanced, existing networks. And to help communities improve their coordination
and collaboration between responders and service providers. And hereís an example of one of our resources. And thatís easily found online at consumerfinance.gov. And fast forward one more. To find a network if you want to connect with
a network, I recommend the national, one-stop shop at Eldercarelocator.alc.gov. Elder Care Locator is also a great way to
find out who to report to locally. You can go in there, put in the zip code of
where you are or where the victim is, and it will bring up a list of services. And, be aware of the different services that
are provided to older people through your local area Agencies on Aging. And you will find elder abuse as of one of
the options. And if you click on that youíll find a contact. And then through there you can ask about a
local network or, you can report your concerns about an older person or older account holder. At this point I will turn it over to David
from the FDIC.>>>>>>Good afternoon and thank you for joining
our Webinar. Iím David Ramos with Community Affairs here
at the FDIC. Iím going to be sharing an overview of the
Money Smart for Older Adults curriculum, and outline related resources available. The Money Smart for Older Adults curriculum
was developed jointly by the FDIC and CFPB as an instructor-led training with the purpose
of raising awareness on how to prevent elder financial exploitation, and encourage advanced
planning and informed decision-making. We are excited to share with you a recent
accolade reached by the Money Smart for Older Adults Program earlier this year. The Cavanaugh Award is presented annually
to an individual or organization demonstrating continued excellence in training and education
in the field of aging, by the American Society of Aging. The CFPB and the FDIC were recipients of the
2019 Gloria Cavanaugh Award for Excellence in Training and Education for the Money Smart
for Older Adults Program. Weíre also excited that the MSOA has recently
achieved a new milestone, having recently registered one million copies of distribution
of both print and downloadable materials. The program objectives of the MSOA module
are that upon completion of the course, participants will be better able to recognize and reduce
the risk of elder financial exploitation; guard against identity theft; plan for unexpected
loss of the ability to manage their finances; prepare financially for disasters; and find
other helpful resources on managing money and reporting financial exploitation. On your screen youíll see a list of topics
addressed throughout the curriculum. Topics such as common types of financial exploitation,
scams that target home owners, scams targeting veterans, planning for unexpected life events,
and how to be financially prepared for disasters. The MSOA module is made up of three components. An instructor guide that is fully scripted,
enabling professionals from many disciplines to begin teaching the module right away. A participant resource guide that supports
classroom instruction by providing key takeaways and can also be distributed to older persons
and others, on its own. And the PowerPoint presentation that supplements
classroom instruction. Please know that the instructor guide and
resource guide are in 14 point font, making it easier to read, which means that the instructor
guide and the supporting material are older adult friendly documents. Additionally, the material is also available
in Spanish. The MSOA Instructor Guide is designed to prepare
and assist the instructor with the delivery of the curriculum. Displayed on your screen are the major areas
of the instructor guide. I will discuss the first three on our list
to give you an idea of what tools are available to the instructor. The first one, the presentation planning guide,
breaks down the module by topic, into separate sections. Each topic has an approximate completion time
listed to help the instructor plan to deliver the course within the allotted time necessary. The second bullet point, the instruction icon
guide, lists the icons used throughout the guide to indicate the activity type related
to a specific topic to support participantís learning. And the third one is the Module Overview,
which lists the purpose and learning objectives for each section, presentation time, module
activities, and training tips to help guide the course. The Participant Guide contains information
and activities to help learn the material, tools and instructions to complete the activities,
a glossary of the terms, resources on managing money and reporting financial exploitation. Also, the Resource Guide serves as a standalone
handout for distribution to older people and others within their caregiver network. The image on your screen is an example slide
from the PowerPoint deck of the actual curriculum titled, Examples of Financial Exploitation. The presentation slide provides examples of
common financial exploitation practices such as exploitation by an agent under a POA or,
person in a fiduciary capacity. It mentions investment fraud and scams, theft
of money or property by family members, caregivers, or in-home helpers. It also mentions lottery and sweepstakes scams,
like we pointed out earlier. These are just a few examples of money financial
exploitation scams that the curriculum addresses to make the audience aware of the various
deceptive practices that older adults fall victim to. Additionally, the material aims to provide
safeguards to avoid these scams, and information in the unfortunate event that someone falls
victim to such practices. Money Smart for Older Adults curriculum is
a tool designed to be shared with older adults, their caregivers and the community organizations
who support the population. There are two key delivery options that can
be used. First, independently by service providers
or community organizations. Second, as a tool for community partnerships
with financial institutions. For example, financial institutions can sponsor
events and deliver information in collaboration with adult protectives, law enforcement, or
senior service providers. During the delivery of the course it allows
for law enforcement and adult protective service responders to introduce their agency and share
local stories, meet privately with participants, and engage with a multidisciplinary team. We find that sharing the curriculum with trusted
partners with the communities we serve, delivers the best outcomes. On your screen weíre showing you examples
of such venues, in the event your organization is considering conducting a Money Smart for
Older Adults seminar. And if you would like to order the material,
you can simply download the training module from the FDIC. Additionally, you can order publications,
including the Money Smart for Older Adults Participant Resource Guide, directly from
the CFPB. The option to order single or bulk hard copies
in Spanish and English materials, free of charge, is available. Please order four to six weeks in advance
of your trainings, senior fairs, and scam prevention events to allow ample time for
delivery of the material. We have the Money Smart Alliance which is
the FDICís way of recognizing organizations that contribute to the delivery of the Money
Smart curriculums to consumers and small businesses. Alliance members agree to use or promote the
Money Smart curriculum by teaching Money Smart or training others to teach it. Alliance members also provide feedback and
successful uses of the program to the FDIC to help improve the Money Smart Program. We also have the Money Smart News. This is how we share stories about organizations
that use Money Smart for Older Adults to help prevent elder financial abuse and other Money
Smart products. And at this point I would like to turn it
over to Luke to close us out. And we thank you for your time.>>>>>>Thank you everyone for participating. Unfortunately, we do not have time to answer
any questions right now. And additionally, once the WebEx Chat is closed,
we probably wonít be able to respond to specific questions. However, we will review them and use those
as content for future Webinars and future communications. As always, if you have a specific question,
you can reach out to your federal regulator ñ FDIC, OCC, NCUA, or the FRB. FinCEN also has a Resource Center you can
call with specific questions about bank secrecy and SARs. Anyone who needs the PowerPoint can email
Community Affairs at FDIC.gov, if you did not already. If you need an audio file, you can email any
of us. I cannot guarantee we can provide the audio
file because the possibility of technical issues, but we hope to make it available in
two to three weeks. Again, if you email us, weíll put you on
the waitlist to get it. And if we canít make it available, weíll
let you know as well. Thank you everyone for participating. We appreciate your time and we hope you have
a great rest of the day and week.>>>>>>Thank you. And that concludes todayís conference. You may all disconnect at this time.

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