Materials for the SIFMA Senior Investor Protection Conference
Panel: FINRA Rule 2165 – Report & Hold
Panelists will discuss the implementation of Rule 2165, which provides a safe harbor for firms to place a temporary hold on disbursements when senior financial exploitation is suspected. This discussion will include identifying instances to utilize the hold, as well as actions the firm can take once the hold is in place.
- CLE Deck – FINRA Rule 2165 Report & Hold (pdf)
- Regulatory Notice 07-43: FINRA Reminds Firms of Their Obligations Relating to Senior Investors and Highlights Industry Practices to Serve these Customers (pdf)
- Regulatory Notice 09-42: FINRA Reminds Firms of Their Obligations With Variable Life Settlement Activities (pdf)
- Frequently Asked Questions Regarding FINRA Rules Relating to Financial Exploitation of Senior Investors (pdf)
- GLBA – Sec 502 (pdf)
- HB 93/GA (pdf)
Panel: FINRA Rule 4512 – Trusted Contact
Panelists will discuss the implementation of Rule 4512, which requires firms to request information about a “trusted contact” for senior clients as a resource for protecting assets and responding to suspected financial exploitation. This discussion will include how to have the conversation with clients, as well as when and how the institution will utilize the contact information.
- Regulatory Notice 11-52: FINRA Reminds Firms of Their Obligations Regarding the Supervision of Registered Persons Using Senior Designations (pdf)
- Frequently Asked Questions Regarding FINRA Rules Relating to Financial Exploitation of Senior Investors (pdf)
- GLBA – Sec 502 (pdf)
- CLE Deck – FINRA Rule 4512 Trusted Contact (pdf)
- Regulatory-Notice-16-12: Pension Income Stream Products (pdf)
- Toolkit Model Trusted Contact Authorization (doc)
Panel: Anatomy of an Investigation
This panel will describe what investigations into senior financial exploitation look like from the perspective of financial firms, adult protective services, and law enforcement. Panelists will discuss what is involved, how an investigation may differ from another, and more.
- Penal Law Compilation (pdf)
- Protecting Vulnerable Adults from Suspected Financial Exploitation
- CLE Deck – Anatomy of an Investigation (pdf)
- Laws of New York – APS (pdf)
- Criminal and Adult Protection Financial Exploitation Laws in the US (pdf)
- Regulatory Notice 17-11: SEC Approves Rules Relating to Financial Exploitation of Seniors (pdf)
- S 2155 – SeniorSafe Act (pdf)
- PLAW-115 70 Pub – ELDER ABUSE PREVENTION AND PROSECUTION ACT (pdf)
- Adult Protective Services Brochure (pdf)
- FAQS – ELDER ABUSE ENHANCED MULTIDISCIPLINARY TEAMS (doc)