Financial exploitation is a rapidly growing form of abuse of seniors.
And firms like Wells Fargo, Edward Jones, Fidelity Investments, LPL Financial and Morgan Stanley Wealth Management are responding by developing unique training programs on the specific needs of senior investors and building a senior investor protection framework within their organizations.
A panel discussion during SIFMA’s recent Senior Investors Forum revealed the different initiatives these firms have taken to train their staffs to handle financial exploitation of seniors. Across the board, the firms have some sort of training that includes how to identify red flags and,once identified, then take the appropriate escalation steps.
“From an Edward Jones standpoint, we definitely educate our financial advisors but we don’t empower them,” said John Ellis, principal at Edward Jones. Adding, “We want the empowerment to rest with the supervisors because we don’t want [advisors] put in the position where they have to diagnose clients. They can’t do that, they’re not medical professionals. It is about noticing issues and escalating where appropriate.”
The same goes for the other firms: LPL advisors escalate to their supervisory principal; Fidelity requires escalation to a centralized group; Morgan Stanley uses its advisory legal team as the escalation point.
Many of these firms also have designated teams in place to deal with senior investors’ issues and suspected financial exploitation cases.
Edward Jones is working on a “virtual counsel” that would bring together about nine to 10 people from legal, compliance, marketing and training teams to deal with the senior investor issues holistically, Ellis said. Ellis said Edward Jones has seen several hundred cases “at least” where there was “reasonable suspicion” that there was financial exploitation or fraud or abuse of an elder client.
LPL has a Senior Investors and Advisors Compliance department, which includes Timothy Keeton, the assistant VP of senior investors. Keeton works closely with the six or seven members on the financial investigation unit if a financial exploitation of a senior merits investigation.
Kim Perry, a VP at Fidelity Investments, said Fidelity has a team of 12 associates which handles escalations from suspected elder financial abuse cases. In addition, Fidelity has risk managers and lawyers who provide advice and guidance, as well as a team that handles the elder exploitation investigation and can them make referrals to Adult Protective Services and law enforcement.
While Morgan Stanley doesn’t currently have a dedicated group handling elder abuse issues, Rocco Procopio, executive director and head of the Field Compliance Department at Morgan Stanley, said the firm has a “virtual team of legal, compliance and risk” members. Several of the firm’s attorneys and compliance staff are trained for escalations.
Panel moderator Ronald Long, senior VP and director of regulatory affairs and elder client initiatives at Wells Fargo Advisors, LLC, added that Wells Fargo Avisors also has a “sizable team” of nine people that may well grow larger. Long said Wells Fargo Advisors is “on a pace to hit 1,800 of those cases this year,” adding that 55% to 60% of those cases get referred to Adult Protective Services, securities regulators or law enforcement.
Each firm also has a slightly different approach to how it addresses the growing issue of financial exploitation of seniors. Here are some highlights of each of those firms’ different approaches.
At Edward Jones, Ellis said the firm started “baking in” senior investor topics into CE courses that escalated to a standalone CE course on senios investors in 2008 and again in 2014.
“We came back to the topic this year and realized that we can probably do something that is permanent every year and make it dynamic,” Ellis said. “That was the concern originally: How do you make a CE course about a topic dynamic to do it every year? We figure with the different scenarios and developments taking place we can do that so we’ll have a standalone CE course [on senior investors].”
Ellis said they’re developing the course internally, but it “will encompass what’s going on out there in the senior investor space.”
The course will be designed for all of Edward Jones’ advisors, assistants and branches, as well as any licensed people in the firm’s home office, which would include the supervisor and compliance personnel.
LPL created Keeton’s role on the independent BD’s Senior Investors and Advisors Compliance unit last year. Under this role, Keeton develops policies, best practices and training, as well as acts as primary advisor and point of contact on elder financial abuse cases. He also works very closely with LPL’s financial investigations unit, which would handle any fraud investigation.
“One of the things that we talk very strongly about is to ‘document, document, document,’” Keeton said. Advisors dealing with senior clients should document, he said, for “their own protection, for the protection of the client, for establishing a baseline of behavior and to be able to look back at your notes and see where a situation has progressed.” Another best practice Keeton suggests for advisors is that after meeting an older client, the advisors should send the client “some sort of follow-up that reiterates what it was that they talked about, what action they took, what they did.”
When it comes to training on working senior investors, Perry says she came to the conclusion that “one and done” is not enough.
“In order for this to be on the minds of our associates who have a lot of things they need to be remembering at all times, we really needed to do more than one annual online training,” she said. While the annual training continues, Fidelity looked to develop a broader program that she says “got this issue in front of our associates as often as possible and in as many different ways as possible without it becoming white noise, which can be a challenge as well.”
One way Fidelity accomplished this was through computer screensavers and digital signage in Fideliity’s offices during a couple different months out of the year. The screensavers might include a tagline “Help Fidelity’s older customers” along with a statistic or red flag.
While Morgan Stanley has included annual training regarding senior investor issues in its training for new hires for several years, the firm started getting requests from its advisors that the one-time training wasn’t enough.
From there the firm created an internal website that includes resources and a desk reference for each FA and branch manager.
The financial advisor version reminds advisors of red flags, Procopio said. “When you start noticing [a red flag] is when we want you to get management involved.” The branch manager version is more about “continuing to stay in front of their financial advisors” on the issue, he said.
Procopio stressed the importance of continuing to put education on elder financial abuse in front of its advisors and managers.
“Legal and Compliance can create resources but it’s on-the-ground management teams that are seeing things – whether it’s on reports, dialogue or seeing the client in the office. It’s putting out reminders of the signs they should be looking for.”
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