FINANCIAL EXPLOITATION _________________________

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FINANCIAL EXPLOITATION_________________________

• RECOGNITION, PREVENTION, RESPONSES AND
  CONSEQUENCES

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• 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
• melissa.lader.barnhardt_at_suntrust.com

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IT IS TIME TO OPEN OUR EYES AND OUR
MOUTHS___________________________________________
______________

• 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__________________________
______________________

• 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_____________________
___________________________

• 1. 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.
• 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______________________
__________________________

• 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______________________
__________________________

• 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______________________
__________________________

• (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____________________________
_________________________

• 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
  ADULTS FUNDS, PROPERTY OR ASSETS AND,
• D. OBTAINING OR USING AN ELDERLY PERSONS
  OR DISABLED ADULTS 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 PERSONS
  DISABILITY IS NOT A DEFENSE!!!!!!

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APPLICABLE STATE LAWS____________________________
____________________

• 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 ADULTS
  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____________________________
____________________

• 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____________________________
____________________

• 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 30S WHO SAYS SHE
  IS MARRIED AND NEEDS IT FOR HER SICK CHILD.
  CLIENT TELLS YOU, BUT DOESNT WANT TO GET HER IN
  TROUBLE. THE PERPETRATOR DOESNT 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?
_________________________________________________

• Exploiters come in all shapes, sizes
  and colors
• THEY INCLUDE
• SONS DAUGHTERS ) FAMILY MEMBERS MAKE
• BROTHERS SISTERS ) UP 80 OF ALL EXPLOITERS!
• FAMILY CAREGIVERS )
• NEIGHBORS
• ACQUAINTANCES
• STRANGERS

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EXPLOITATION STATISTICS________________
________________________________

• 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?____________________________________________
__________________DIRECT EXPLOITATION BY
INDIVIDUAL1. UNUSUAL ACTIVITY IN BANK
ACCOUNTS2. 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 OLDWITH PARKINSONS DISEASE
4. NEWLY DRAFTED POWERS OF ATTORNEY OR CHANGES
OR CREATION OF A WILL WHEN AN ELDERS DECISION
MAKING ABILITIES ARE IN QUESTION A. SON
REMOVED ALL ASSETS FROM ACCOUNT,
TRANSFERREDHOUSE TO HIMSELF, AND MADE HIMSELF
SOLE BENEFICIARYOF IRAS
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__________________________________________________
__
WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?

• B. FLA NOW HAS SPRINGING POA REQUIRING AN
  AFFIDAVITFROM PHYSICIAN ATTESTING TO ELDERS
  INCAPACITY MUST BE PRIMARY PHYSICIAN5. UNPAID
  BILLS, WHEN SOMEONE SHOULD BE PAYING THEM
• A. DCF CALLED IN WHEN LANDLORD REPORTED
  THAT VICTIMS 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 VICTIMS
  WEDDING RING

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WHAT DOES FINANCIAL EXPLOITATION LOOK LIKE?
__________________________________________________
_______

• 8. DELIBERATE ISOLATION BY FAMILY MEMBER OR
  HOUSEKEEPER
• A. SYSTEMATIC ATTEMPTS TO SEQUESTER VICTIM
  FROM REST OF WORLD - CANT 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?____________________________________________
______________

• 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____________________________
_________________________

• 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 [phone] (MUST LEAVE A
  RETURN FAX)
• 1. WHAT YOU WILL NEED WHEN YOU CALL
• a. VICTIMS NAME,
  ADDRESS/LOCATION, APPROX. AGE
• RACE, SEX
• b. BRIEF DESCRIPTION OF VICTIMS
  DISABILITY
• c. SIGNS OR INDICATIONS OF HARM
  OR INJURY

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AVAILABLE PROTECTIONS____________________________
___________________

• 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____________________________
___________________

• 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____________________________
___________________

• 5. FILE LAWSUIT TO RECOVER ASSETS
• 5. CRIMINAL RESPONSES
• A. LAW ENFORCEMENT INVESTIGATION
• B. STATES ATTORNEYS 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 GENERALS OFFICE WILL PURSUE
  ACTIONS AGAINST NURSING HOMES/ASSISTED LIVING
  FACILITIES WHERE SUSPICION OF EXPLOITATION BY
  EMPLOYEE

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AVAILABLE PROTECTIONS____________________________
___________________

• 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_____________________
___________________________

• Training for Employees All Areas of the Bank
• RESOURCES TRIAD PROGRAMS BSAFE
• FLAG
• BANKERS ASSOCIATIONS (CALIFORNIA)
• E- BASED TRAINING
• GOVERNMENT AGENCIES (APS)
• LAW ENFORCEMENT
• PUBLIC GUARDIANS OFFICE/STATE GUARDIAN
• LOCAL COALITIONS

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BANK POLICIES AND PROCEDURES_____________________
___________________________

• Internal Website with State Specific Requirements
  on Reporting and Definitions of Abuse, Neglect
  and Exploitation
• Internal Website with Risk Identifiers and
  Examples
• Listing of Contact Information for Hotline
  Reporting and Resources
• Establish Internal Legal/Security Contacts to
  Discuss Issues as They Arise
• Establishment 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 Generals Office. (California
  Bankers Association)

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CLIENT EXAMPLES__________________________________
__________________

1. A 75 year old lady who suffered from moderate
   stage Alzheimers 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
   victims 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 sons 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__________________________________
__________________

• 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 Alzheimers
  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__________________________________
______________

• 3. Customer has a special needs trust with 2
  million in it for a young woman in her early 20s
  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 wouldnt
  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
  attorneys 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_____________________________
______________________________________________

• 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!