FinXTech’s Need to Know: Elder Finances

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There’s a bit of a conundrum in the financial technology space. As more services move to the digital realm, the premise is that they become more accessible and relevant to a broader audience — specifically, millenials and Gen Z.

But self-servicing digital experiences don’t necessarily benefit an aging population.

A 2016 study from the U.S. Census Bureau reports almost 50 million adults 65 years and older are living in the U.S. That number is projected to surpass 100 million by 2060, which will outnumber the amount of children under 18 in the U.S.

There is no set age that represents an older adult’s inability to manage their finances — I know friends today who handle their parents’ finances while they are in their mid-forties, and also have a colleague whose father can still write checks at 90. Banks have an opportunity to facilitate the transition of financial management from adult to caregiver, and ensure that those customers stay with the bank.

Fintechs that specialize in the management and monitoring of elder finances can help banks ease the burden of that transition.

There are three main ways that fintechs can work with banks in this space: They can provide a digital banking platform tailored toward elder populations, they can monitor transactions for fraud and they can provide financial advisory services or planning.

Banks can work with fintechs to provide a digital banking interface that organizes elder finances for account holders. Managing insurance, retirement, medical, housing and emergency costs can feel next to impossible for caregivers who suddenly gain access to elder accounts. But, being able to access and manage those accounts from one platform could save time and prevent a potential headache.

Carefull is one such digital banking platform. Accounts can be set up by the elder themselves, with assistance or by a caregiver. From the platform dashboard, users can access past and future bills, income, deposits, assets and transactions made. An extra layer of transaction and fraud monitoring alerts users when suspicious activity is detected.

Multiple users can be added to the account on a view-only basis, and transactions can not be initiated or carried out by anyone except the elder within the Carefull platform. Users can even connect with financial advisors and planners within the bank.

Elder fraud can be extremely difficult to spot, and increasingly common. A 2019 report from the Consumer Financial Protection Bureau looked at Suspicious Activity Reports (SARs) that dealt with elder financial exploitation from 2013 to 2017. The study found that filings quadrupled within those four years, and that those reported accounted for only a fraction of incidents.

When elder fraud occurs — whether it be malicious (from a bad actor), a crime of opportunity (from a caregiver) or a self-induced mistake (falling for a phishing scam) — the losses are apparent. The average lost in each SAR totaled $34,200. Losses were greater when the elder knew the perpetrator versus a stranger: $50,000 compared to $17,000.

EverSafe works as a second set of eyes on bank, investment, retirement and credit card accounts. Its analytics technology looks for irregularities within transactions, transfers or withdrawals made from each account, and sends alerts to a trusted caregiver, whether it be a spouse, child or hired help. EverSafe, with a partner bank, can also help guide families through remediation processes when fraud or theft occurs, and in some cases will reimburse lawyer fees.

Banks can take a proactive approach with aging populations with fintechs that offer advisory services — assisting with in-person advisors or through artificial intelligence. Genivity’s HALO platform operates as a software-as-a-service solution that helps bank customers plan for the biggest risks to their longevity, health and finances. Each customer receives a personalized report that includes how many years they are expected to live with assistance and its cost, including out-of-pocket expenses.

Full reports are given to financial advisors, so that clients are incentivized to speak with them about their future financials. HALO can be white-labeled and embedded directly into a bank’s digital platform.

Banks will have to strengthen their reactive and proactive strategies when it comes to protecting and catering to aging populations — and partnering with a fintech may be the best way forward for many. Doing so may help banks accumulate life-long customers across generations.

Carefull, EverSafe and Genivity are all vetted companies for FinXTech Connect, a curated directory of technology companies who strategically partner with financial institutions of all sizes. For more information about how to gain access to the directory, please email [email protected].

Protecting Elderly Customers from Financial Abuse

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regulation-2-28-18.pngRegulators across the financial services industry remain keenly focused on protecting the interests of an aging population, especially where there may be signs of diminished cognitive capacity. Banks should consider various operational and compliance measures to guard against elder financial exploitation. While bank staff are on the front lines in protecting elderly customers, bank directors play a pivotal, top-down role in emphasizing a culture of vigilance, and in defining policy and strategy to combat elder financial fraud.

Be Aware of the Problem
Frontline personnel in branches and call centers are the first and last lines of defense to prevent elder financial exploitation. These personnel are the most likely to interact with elderly clients, many of whom are more inclined to conduct their financial transactions in a branch or over the phone, rather than electronically. Conducting periodic training that highlights real-world scenarios will help personnel recognize the signs of elder financial exploitation. An additional training element that may prove beneficial, but that often goes overlooked, is educating personnel on the psychological and emotional aspects of elder fraud. A customer’s diminished cognitive capacity or potential confusion, fear or embarrassment may be central to a perpetrator’s ability to prey on an elderly client.

Empower Employees to Speak Up
Identifying signs of potential financial exploitation of elderly clients is a great start. However, it is critical that personnel escalate suspicious activity through the proper channels within the bank. Personnel may be reluctant to follow through with escalating an event that is not blatantly fraudulent, perhaps out of fear of delaying a transaction or potentially embarrassing or even angering a client. However, speaking up is prudent, even when in doubt.

Develop the Three Ps
Banks should develop policies, processes and procedures that are easy to understand and follow.

Policies: Clearly define your organization’s views, guidelines and stated mission with regard to elder financial fraud.

Processes: Identify the mechanisms in place to effectively carry out the bank’s stated policies. This may include pre-set withdrawal limits (either daily or monthly), disbursement waiting periods or communications with external sources, such as a trusted contact person for the client, local adult protective services (APS) or law enforcement.

Procedures: Describe the precise steps that personnel should follow to execute the identified processes. What must a teller do in the event that a withdrawal request exceeds an established limit? Who does a call center representative contact in the event of suspicious activity, and what information should be provided? What information should personnel provide to a trusted contact person? What reports must be filed with authorities?

Report Suspected Exploitation
Banks are subject to various reporting requirements at the state and federal levels that relate to suspected elder financial fraud. National banks, state banks insured by the Federal Deposit Insurance Corp. and other financial institutions must file a suspicious activity report (SAR) with the Financial Crimes Enforcement Network (FinCEN) upon detection of a known or suspected crime involving a transaction. FinCEN has provided related guidance, and the electronic SAR form includes an “elder financial exploitation” category of suspicious activity. Several states’ laws and regulations also require that banks report suspected elder abuse to APS or law enforcement.

Banks may consider permitting clients to identify a “trusted contact person” that the bank may contact upon reasonable suspicion of potential exploitation. This is consistent with a March 2016 advisory from the Consumer Financial Protection Bureau (CFPB). Privacy concerns exist when disclosing customer information to a third party. However, the Gramm-Leach-Bliley Act (GLBA) permits disclosure of nonpublic personal information with customer consent. Regulation P under GLBA also grants an exception to the notice and opt-out requirements to protect against fraud or unauthorized transactions, or to comply with federal, state or local laws, rules and other applicable legal requirements. Additionally, 2013 Interagency Guidance “clarifies that reporting suspected financial abuse of older adults to appropriate local, state or federal agencies does not, in general, violate the privacy provisions of the GLBA or its implementing regulations.” A safe harbor from liability also exists for a bank that voluntarily discloses a possible violation of law or suspicious activity by filing a SAR. Bank personnel are also protected from liability in this situation.

Regulators at all levels of, and sectors within, the financial services industry continue to prioritize the interests of elderly customers, especially where there may be signs of diminished cognitive capacity. The banking community has gone to great lengths to support these efforts, and bank directors will continue to play an important role in defining internal policies and emphasizing the importance of vigilance in this area.