Transcript TOOLS FOR ADVANCED CHARITABLE PLANNING

FINANCIAL
EXPLOITATION
_________________________
RECOGNITION, PREVENTION,
RESPONSES AND CONSEQUENCES
SUNTRUST BANK
Material Preparation
Melissa Lader Barnhardt, J.D., LL.M
Terry Abrams Berger, Esq.
Dr. Jean Sherman
Coalition to Prevent Abuse of Vulnerable Adults
of Miami-Dade and Monroe Counties
(CPAVA)
Presentation By:
Melissa Lader Barnhardt, J.D., LL.M
First Vice President & Trust Advisor
954-765-7344
[email protected]
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IT IS TIME TO OPEN OUR EYES AND OUR MOUTHS
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EXPLOITATION STATISTICS
NATIONAL CENTER ON ELDER ABUSE AND FLA. DEPT OF ELDER
AFFAIRS CALLS ELDER EXPLOITATION
THE CRIME OF THE 21ST CENTURY
NUMBER OF ELDERLY WILL DOUBLE TO 70 MILLION WITHIN
NEXT 30 YEARS; HIGHEST GROWTH RATE FOR THOSE OVER 80
MEDIAN NET WORTH OF OLDER HOUSEHOLDS IS 2 TIMES
NATIONAL AVERAGE - CRIMINALS FOLLOW THE MONEY
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AGENDA FOR PRESENTATION
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I.
APPLICABLE FEDERAL & STATE LAWS
II.
STATISTICS, IDENTIFICATION AND RECOGNITION
OF FINANCIAL EXPLOITATION
III.
AVAILABLE PROTECTIONS
IV.
BANK RESPONSIBILITY/PROCEDURES
V.
CASE EXAMPLES
VI.
QUESTIONS & ANSWERS
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APPLICABLE FEDERAL STATUTES
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FEDERAL DEFINITION – PROVIDED BY THE OLDER AMERICANS
ACT, 42 U.S.C. 3002 (24) - The term “exploitation” means the illegal or
improper act or process of an individual, including a caregiver, using the
resources of an older individual for monetary or personal benefit, profit or gain.
1.
2. RIGHT TO FINANCIAL PRIVACY ACT – 12 U.S.C. Sec. 3401 et. Seq.
3403. Confidentiality of financial records
Nothing in this chapter shall preclude any financial institution, or any officer,
employee, or agent of a financial institution, from notifying a Government
authority that such institution, or officer, employee, or agent has information
which may be relevant to a possible violation of any statute or regulation. Such
information may include only the name or other identifying information
concerning any individual, corporation, or account involved in and the nature of
any suspected illegal activity.
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APPLICABLE FEDERAL STATUTES
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Such information may be disclosed notwithstanding any constitution, law,
or regulation of any State or political subdivision thereof to the contrary.
Any financial institution, or officer, employee, or agent thereof, making a
disclosure of information pursuant to this subsection, shall not be liable to
the customer under any law or regulation of the United States or any
constitution, law or regulation of any State or political subdivision thereof,
for such disclosure or for any failure to notify the customer of such
disclosure.
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APPLICABLE FEDERAL STATUTES
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3. Financial Services Modernization Act of 1999 (known
as the Gramm-Leach-Bliley Act) 15 U.S.C. Subchapter 1
Sect. 6801-6809
Sec. 6802. Obligations with respect to disclosures of personal information

(e) General exceptions

Subsections (a) and (b) of this section shall not prohibit the disclosure
of nonpublic personal information

(e)(3)(B) to protect against or prevent actual or potential fraud,
unauthorized transactions, claims, or other liability.
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APPLICABLE FEDERAL STATUTES
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(e)(5) to the extent specifically permitted or required under other
provisions of law and in accordance with the Right to Financial Privacy
Act of 1978 (12 U.S.C. 3401 et seq.), to law enforcement agencies
(including a Federal functional regulator).
(e)(8) to
comply with Federal, State, or local laws, rules, and other
applicable legal requirements; to comply with a properly authorized civil,
criminal, or regulatory investigation or subpoena or summons by Federal,
State, or local authorities; or to respond to judicial process or government
regulatory authorities having jurisdiction over the financial institution for
examination, compliance, or other purposes as authorized by law.
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APPLICABLE STATE LAWS
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1. FLORIDA CRIMINAL STATUTES: Fla. Stat. Section 825
A. TAKING FINANCIAL ADVANTAGE OF A PERSON OLDER THAN 60 OR A
PERSON WITH A DISABILITY WHO IS NOT IN COMPLETE COMMAND OF
HIS OR HER MENTAL AND/OR PHYSICAL FACULTIES;
B. THE INTENTIONAL THEFT OF MONEY OR PROPERTY FROM A
VULNERABLE PERSON AFTER GAINING HIS OR HER TRUST (ALSO
CALLED: FINANCIAL MISTREATMENT, OR FIDUCIARY, ECONOMIC,
FINANCIAL OR MATERIAL ABUSE);
C. ILLEGAL OR IMPROPER USE OF A VULNERABLE ADULT’S FUNDS,
PROPERTY OR ASSETS; AND,
D. OBTAINING OR USING AN ELDERLY PERSON’S OR DISABLED ADULT’S
FUNDS, ASSETS OR PROPERTY BY A PERSON WHO KNOWS OR
REASONABLY SHOULD KNOW THAT THE ELDERLY PERSON OR
DISABLED ADULT LACKS THE CAPACITY TO CONSENT.
NOT KNOWING THE AGE OR EXTENT OF A PERSON’S DISABILITY IS NOT A
DEFENSE!!!!!!
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APPLICABLE STATE LAWS
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2. ADULT PROTECTIVE SERVICES – FLA. STAT. SEC. 415.102(7)(a):
A. SOMEONE STANDING IN A POSITION OF TRUST TO A VULNERABLE
ADULT;
B. KNOWINGLY OR BY DECEPTION OR INTIMIDATION;
C. OBTAINS OR USES A VULNERABLE ADULT’S FUNDS, ASSETS OR
PROPERTY;
D. WITH AN INTENT TO PERMANENTLY DEPRIVE THE VULNERABLE
ADULT OF THE USE, BENEFIT OR POSSESSION; AND,
E. TO THE BENEFIT OF SOMEONE OTHER THAN THE VULNERABLE
ADULT.
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APPLICABLE STATE LAWS
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3. FLA. STAT. SEC. 415.02(10) DEFINES FIDUCIARY RELATIONSHIP
A. TRUST OR CONFIDENCE BY THE VULNERABLE ADULT IN THE
CAREGIVER, RELATIVE, HOUSEHOLD MEMBER OR OTHER PERSON
ENTRUSTED WITH MANAGEMENT OF THE PROPERTY OR ASSETS OF THE
VULNERABLE ADULT.
B. THERE IS TRUST OR CONFIDENCE IN THAT PERSON THAT HE/SHE IS
BOUND TO ACT IN GOOD FAITH.
C. AUTOMATIC FIDUCIARY RELATIONSHIPS INCLUDE COURT
APPOINTED OR VOLUNTARY GUARDIANS, TRUSTEES, ATTORNEYS, OR
AGENTS UNDER POWERS OF ATTORNEY.
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APPLICABLE STATE LAWS
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4. FLA. STAT. SEC. 415.1034 MANDATORY REPORTING
A. MANDATED REPORTER VS. PERMISSIVE REPORTER
B. IMMUNITIES (REPORT IN GOOD FAITH)
C. CRIMINAL PENALTIES FOR FAILURE TO REPORT
D. ISSUES – PRIVILEGES/FEDERAL LAWS
E. PROBLEMS WITH REPORTING – PERSON TELLS YOU NOT TO CALL
EXAMPLE: BANK OFFICIAL RECEIVES REPORT THAT CLIENT, WHO IS 90
YEARS OF AGE, BUT COMPETENT, IS LOANING MONEY TO A WOMAN IN
HER 30’S WHO SAYS SHE IS MARRIED AND NEEDS IT FOR HER SICK CHILD.
CLIENT TELLS YOU, BUT DOESN’T WANT TO GET HER IN TROUBLE. THE
PERPETRATOR DOESN’T FALL WITHIN THE DEFINITION OF THE STATUTE
SO A REPORT TO APS WILL NOT SUFFICE, WHAT CAN BE DONE?
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WHO IS THE EXPLOITER?
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Exploiters come in all shapes, sizes and colors:
THEY INCLUDE:
SONS
& DAUGHTERS
BROTHERS & SISTERS
FAMILY CAREGIVERS
NEIGHBORS
ACQUAINTANCES
STRANGERS
SUNTRUST BANK
) FAMILY MEMBERS MAKE
) UP 80% OF ALL EXPLOITERS!
)
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EXPLOITATION STATISTICS
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76%
OF VICTIMS ARE BETWEEN AGES 70 & 89
WOMEN
FALL PREY TO EXPLOITATION TWICE AS MUCH AS MEN
83%
OF VICTIMS ARE WHITE; 17% FROM OTHER BACKGROUNDS
60%
OF PERPETRATORS WERE ADULT CHILDREN
35% WERE
OTHER RELATIVES, INCLUDING GRANDCHILDREN,
FRIENDS, NEIGHBORS, AND CAREGIVERS
REMAINDER WERE
UNKNOWN (TELEMARKETERS)
ESTIMATED THAT 80%
OF ALL CASES GO UNREPORTED
THE ICEBERG THEORY. WHY?
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WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?
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DIRECT EXPLOITATION BY INDIVIDUAL
1. UNUSUAL ACTIVITY IN BANK ACCOUNTS
2. CAREGIVER ACCOMPANYING VICTIM TO BANK TO WITHDRAW $
3. SIGNATURE ON CHECK THAT DOES NOT RESEMBLE THAT OF VICTIM
A. SIGNATURE ON CHECK CLEARLY NOT THAT OF 93 YEAR OLD
WITH PARKINSON’S DISEASE
4. NEWLY DRAFTED POWERS OF ATTORNEY OR CHANGES OR CREATION OF A
WILL WHEN AN ELDER’S DECISION MAKING ABILITIES ARE IN QUESTION
A. SON REMOVED ALL ASSETS FROM ACCOUNT, TRANSFERRED
HOUSE TO HIMSELF, AND MADE HIMSELF SOLE BENEFICIARY
OF IRAS
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WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?
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B. FLA NOW HAS SPRINGING POA REQUIRING AN AFFIDAVIT
FROM PHYSICIAN ATTESTING TO ELDER’S INCAPACITY –
MUST BE PRIMARY PHYSICIAN
5. UNPAID BILLS, WHEN SOMEONE SHOULD BE PAYING THEM
A. DCF CALLED IN WHEN LANDLORD REPORTED THAT VICTIM’S
ELECTRIC AND WATER TURNED OFF IN MIDDLE OF SUMMER
6. UNUSUAL CONCERN BY CAREGIVER THAT EXCESSIVE $ BEING EXPENDED
FOR CARE
A. GRANDSON REMOVED VICTIM FROM HIGHLY RATED NURSING
FACILITY INTO FACILITY WHERE SHE RECEIVED VERY POOR CARE. COST
SAVINGS OVER 50%; ELDER DIED 3 WEEKS AFTER MOVE
7. .MISSING PERSONAL BELONGINGS
A. CAREGIVER FOUND TO HAVE PAWNED VICTIM’S WEDDING RING
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WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?
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8. DELIBERATE ISOLATION BY FAMILY MEMBER OR HOUSEKEEPER
A. SYSTEMATIC ATTEMPTS TO SEQUESTER VICTIM FROM REST OF
WORLD - “CAN’T COME TO PHONE” “TOO SICK FOR VISITORS” CONTROLS EVERYTHING
9. STRANGERS WITH INCREASED INVOLVEMENT
A. YOUNGER MAN BEFRIENDS VICTIM AFTER LOSS OF HUSBAND,
TAKES CARE OF FUNERAL, CHARGES VICTIM $196K FOR SERVICE
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WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?
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10. CONSUMER FRAUD
A. TELEMARKETING
B. PROVIDING SS # TO GET SOMETHING FREE (IDENTITY THEFT)
C. ENTERING CONTESTS THAT REQUIRE PERSONAL INFORMATION
D. RECOVERY OF UNCLAIMED FUNDS
1. SCAM TARGETING ELDERLY AFRICAN AMERICANS - FLYER
ADVISING OF SLAVE REPARATIONS IF BORN BEFORE 1927. REQUESTED
SENIOR TO COMPLETE FORM AND THEY WOULD RECEIVE $5,000
E. FICTITIOUS IRS FORM ASKING CUSTOMERS OF BANK TO
COMPLETE. THEN PERPETRATOR HAS INFO TO ACCESS BANK ACCOUNT
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AVAILABLE PROTECTIONS
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1. IF THERE IS AN IMMEDIATE RISK OR DANGER, CALL 911!
2. GATHER DOCUMENTATION AND CALL ABUSE HOTLINE
A. FLA LAW REQUIRES ANY PERSON WHO KNOWS, OR HAS REASONABLE
CAUSE TO SUSPECT THAT A VULNERABLE ADULT IS BEING ABUSED,
NEGLECTED OR EXPLOITED SHALL IMMEDIATELY REPORT SUCH
KNOWLEDGE TO THE FLORIDA ABUSE HOTLINE
B. BY TELEPHONE: 1-800-96ABUSE (1-800-962-2873)
C. BY FAX: 1-800-914-0004 (MUST LEAVE A RETURN FAX)
1. WHAT YOU WILL NEED WHEN YOU CALL:
a. VICTIM’S NAME, ADDRESS/LOCATION, APPROX. AGE
RACE, SEX
b. BRIEF DESCRIPTION OF VICTIM’S DISABILITY
c. SIGNS OR INDICATIONS OF HARM OR INJURY
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AVAILABLE PROTECTIONS
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d. NAME, ADDRESS, TELEPHONE OF PERPETRATOR
e. RELATIONSHIP OF PERPETRATOR
f. AS TO THE REPORTER, YOUR NAME, ADDRESS AND TELEPHONE.
THIS INFORMATION IS NEVER GIVEN OUT AND WILL
REMAIN ANONYMOUS
3. ADULT PROTECTIVE SERVICES
A. AN INVESTIGATOR WILL RESPOND WITHIN 24 HOURS
B. WILL INTERVIEW VICTIM AND LEGAL REPRESENTATIVE EITHER BY
PHONE OR FACE TO FACE MEETING
C. WILL REFER TO LAW ENFORCEMENT/SAO IF SOME INDICATORS OF
ABUSE/EXPLOITATION ARE SEEN.
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AVAILABLE PROTECTIONS
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D. WILL MAKE REFERRAL FOR NEEDED SERVICES
E. NOTIFIES PROBATE COURT IF A WARD
F. CAN PROVIDE EMERGENCY RESIDENCE IF NEEDED
G. IF MEDICAID IS INVOLVED, INCIDENT WILL BE REPORTED TO
MEDICAID FRAUD UNIT
4. CIVIL RESPONSES
A. FILE FOR EMERGENCY TEMPORARY GUARDIANSHIP (FLA. STAT. 744)
COURT AS ULTIMATE GUARDIAN CAN TAKE STEPS TO PROTECT WARD
1. STOP AGENT FROM ACTING UNDER POA
2. FREEZE ACCOUNTS
3. STOP SALE OR TRANSFER OF PROPERTY
4. REQUEST AN ORDER OF PROTECTION IF ABUSE IS INVOLVED
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AVAILABLE PROTECTIONS
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5. FILE LAWSUIT TO RECOVER ASSETS
5. CRIMINAL RESPONSES
A. LAW ENFORCEMENT INVESTIGATION
B. STATE’S ATTORNEY’S OFFICE (ECONOMIC CRIMES DIVISION)
1.. WILL PURSUE CRIMINAL ACTION
2. VICTIM DOES NOT HAVE TO PROSECUTE
3. SAO WILL ATTEMPT TO OBTAIN RESTITUTION
C. ATTORNEY GENERAL’S OFFICE WILL PURSUE ACTIONS AGAINST
NURSING HOMES/ASSISTED LIVING FACILITIES WHERE SUSPICION OF
EXPLOITATION BY EMPLOYEE
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AVAILABLE PROTECTIONS
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D. DIFFICULTIES IN MAKING A CASE AGAINST THE PEPETRATOR
1. TIME LIMITATIONS DUE TO AGE OF VICTIM (FL HAS A LAW
ALLOWING SPEEDY TRIAL FOR ELDER VICTIMS)
2. INABILITY OF VICTIM TO TESTIFY BECAUSE OF INFIRMITY OR
CONFUSION
3. FEAR BY VICTIM OF REPRISAL BY PERPETRATOR – ESPECIALLY A
FAMILY MEMBER
4. EMBARRASSMENT OR SHAME AT POSSIBILITY OF PUTTING LOVED
ONE IN JAIL
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PHYSICAL, EMOTIONAL & FINANCIAL CONSEQUENCES
A. CONSEQUENCES OF FINANCIAL EXPLOITATION
1. PHYSICAL
2. EMOTIONAL
3. FINANCIAL
B. INCLUDE:
1. LOSS OF SECURITY, STATUS
2. ABRUPT CHANGE OF LIFESTYLE
3. LOSS OF HOME, SERVICES
C. RESULT IN:
1. DEPRESSION
2. SHAME
3. MALNUTRITION
4. MORTALITY RATES – 3X HIGHER
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BANK POLICIES AND PROCEDURES
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Training
for Employees – All Areas of the Bank
RESOURCES: TRIAD PROGRAMS – B*SAFE
FLAG
BANKER’S ASSOCIATIONS (CALIFORNIA) –
E- BASED TRAINING
GOVERNMENT AGENCIES (APS)
LAW ENFORCEMENT
PUBLIC GUARDIAN’S OFFICE/STATE GUARDIAN
LOCAL COALITIONS
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BANK POLICIES AND PROCEDURES
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Internal Website
with State Specific Requirements on Reporting and Definitions
of Abuse, Neglect and Exploitation;
Internal Website
Listing
with Risk Identifiers and Examples;
of Contact Information for Hotline Reporting and Resources
Establish Internal
Establishment
Legal/Security Contacts to Discuss Issues as They Arise
of Policies and Procedures
A. If suspect a problem, and not an emergency, discuss with your
supervisor (if an emergency, call 911);
B. Document any issues that are red flags and pertinent information;
C. Establish local community resources if unsure of how to proceed
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BANK POLICIES AND PROCEDURES
Check
history on accounts of customer (if not sure, may monitor account and
determine a call is necessary once a pattern is determined). Flag account in notes
section (so other bank personnel are aware).
Develop
an Incident Reporting Form that includes accounts of customer,
problems reported or noticed (dates and times); copies of unusual transactions;
pertinent description of alleged perpetrator (with as much information as you can
gather) and of victim (including appearance, alertness, dress and any specific signs
of abuse or neglect) and any other notes that would be helpful (e.g. Does the
alleged perpetrator allow the person to speak on his/her own?).
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BANK POLICIES AND PROCEDURES
If
customer and alleged perpetrator are present demanding large sums of money, try to stall
the situation and say there is a problem on the account and immediately speak to a supervisor
and/or security/fraud department. The supervisor should say that he/she needs to speak to the
customer alone and try to resolve the problem. If the issue continues ask the customer to
come back the following day. Thereafter, the supervisor and bank personnel should call the
police or hotline after assessing the situation.
Sometimes
there is a fine line as to whether an elder or disabled customer is competent to
make decisions, but if competent, the individual is allowed to make bad judgment decisions.
For example, customer comes in to deposit a check and asks that you wire the proceeds to an
account in Africa. You know of the scams going on with these scenarios and tell the customer
that it is probably too good to be true and they tell you to do the deposit and wire anyway.
This should be discussed with a supervisor and then reported to the fraud unit to contact the
client to assist them in possibly stopping the wire. Hopefully the client will listen, but if not,
there is nothing that can be done other than a report to the Attorney General’s Office.
(California Banker’s Association)
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CLIENT EXAMPLES
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1. A 75 year old lady who suffered from moderate stage Alzheimer’s Disease was
taken to the hospital for a broken nose, which was caused by her son. At first, the
case looked like it was an abuse case and was reported by the hospital to the
hotline. An Emergency Temporary Guardian was appointed and the Temporary
Guardian was given permission to inventory the personal property. The
Temporary Guardian also obtained an order of protection against the son. Criminal
charges were also filed against the son for aggravated battery of an elderly person.
The Temporary Guardian proceeded to perform an inventory and secure the
victim’s real property. Upon going through some paperwork, the Temporary
Guardian discovered a Medicaid Card for the son and a statement from a
brokerage company that was comprised of $800,000 in investments. The name on
the account was in the son’s name. The Temporary Guardian requested
emergency relief to freeze and investigate the asset. It was discovered that the son
had his mother sign a statement (of course her signature was barely legible) to
transfer the assets. Furthermore, the son never reported his new found wealth to
Medicaid. A Plenary Guardianship was later established and the Guardian was
able to recover the funds.
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CLIENT EXAMPLES
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2.
A 97 year old lady was taken to the hospital with a fractured skull caused by her
grandson. The lady was bedridden and suffered from Alzheimer’s Disease. The
grandson lived in the basement of the home. Adult Protective Services was called
and an Emergency Temporary Guardian was appointed. An order of protection
was entered against the grandson, who subsequently pled guilty to aggravated
battery of an elderly person and was sentenced to three (3) years in prison. At the
time of the inventory, it was also discovered that there were new estate planning
documents, including a Durable Power of Attorney for Property and a Trust that
named the grandson as the fiduciary and the beneficiary. The order of protection
also enjoined the agent and trustee from acting under those documents and a
subsequent order was adopted by the Guardianship Court in the Plenary
Guardianship Proceeding. Unfortunately, the victim passed away a few months
later and the issue was turned over to the Probate Court. This case occurred in
Illinois and the grandson did not inherit pursuant to law as his actions were a
contributing factor to her death.
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CLIENT EXAMPLES
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3. Customer has a special needs trust with $2 million in it for a young woman in
her early 20’s who received a settlement from a car accident. She receives SSDI,
Medicare and Medicaid Share of Cost. She recently went through rehab and is an
alcoholic. She was originally living with her mother and was protected. She
subsequently had an argument with her mother and moved in with her boyfriend
who she met in rehab. She would then ask for money as the boyfriend got evicted
from his apartment and would max out her credit card within days ($2,000 limit).
When I wouldn’t continue giving money, she would show up, unannounced at the
bank with the boyfriend requesting funds and requesting my supervisor when I
said “no”. A couple months later we had a meeting at a local branch and I
requested the attorney’s presence. The boyfriend was told by the attorney that he
needed to meet with the customer alone and the boyfriend glared at me and
through the window at her. I then met with the customer and the attorney and she
became very upset and said she needed cash (after we went through the
cash/benefit issues and her spending habits). I noticed some bruising on her and
asked one simple question – “Are you afraid of him?” and that led to an answer of
“afraid to death” and her fear of leaving with him. I called the police, moved her
to a safe place and the attorney helped her get an order of protection.
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PERSONAL INVOLVEMENT
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1. IF A FAMILY MEMBER, STAY INVOLVED IN THE CARE OF THE ELDER,
AND REPORT ANY SUSPECTED ACTIVITY TO THE HOTLINE – ALSO TALK TO
OTHER FAMILY MEMBERS ABOUT THEIR SUSPICIONS
2. IF A CAREGIVER, REPORT SUSPECTED EXPLOITATION TO YOUR
EMPLOYER AND TO OTHER FAMILY MEMBERS
3. IF A PHYSICIAN, LISTEN TO THE ELDER - OFTEN THEY HAVE NO ONE
ELSE TO TALK TO ABOUT THE EXPLOITATION BECAUSE THEY ARE
EMBARRASSED TO TELL THEIR FAMILY
4. IF A NEIGHBOR OR FRIEND, TELL THE FAMILY
5. .IF A BANKER, KNOW YOUR CUSTOMERS - IF YOU SEE SUSPICIOUS
ACTIVITY, REPORT IT TO YOUR EMPLOYER
REMEMBER IF IT LOOKS, FEELS, ACTS OR SMELLS LIKE EXPLOITATION, IT
PROBABLY IS!
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