Compliance: Need to Know - Protecting Your Vulnerable Clients Part I
Mrs. Robinson is late again. Normally, this wouldn’t be concerning, but she missed her last meeting without any notice. She’s a sweet lady, recently widowed, and having patience with her is easy with that warm smile she has.
After 15 minutes, you just surmise that she is not going to make it in today. Again. You feel the need to look out the front door of the office building on the off chance that she is pulling into the parking lot. As you walk down the hallways of your office to the lobby, you notice an older lady going down one of the side hallways.
“Wait a minute,” you think, stopping yourself in mid-stride. You watch the older lady walking away looking like she is lost. It has been a couple of months since you went to Mr. Robinson’s funeral, but that looks like Mrs. Robinson! You walk after her.
“Mrs. Robinson! Mrs. Robinson!”
There seems to be a delayed reaction until she finally turns around.
“Mrs. Robinson, how are you doing today?”
“Fine, fine, but can you help me? I'm looking for Allen and Associates?” she replied.
“Mrs. Robinson, it’s Tom!” you say with a concerned smile. She has been going to your office at least once a year for the past 15 years, and now she’s wandering off on the wrong side of the building.
“Yes, Allen and Associates,” she says.
Then looking up at you, her eyes light up, and with a pat on the shoulder, “Oh, gosh Mr. Allen, you scared me there for a second. I tell you, it must be this weather. My head is all scattered.”
“How about I get you a cup of coffee, and we sit down,” you say in your most assuring voice.
“That would be great, Tom,” with a new-found confidence in her voice.
Most Registered Investment Advisers have seniors as their clients. People that worked hard and saved their money to be able to spend their golden years in somewhat comfort. They entrust their investment advisers to act as their fiduciary, and their livelihood is in your hands. Sadly, seniors are also prime targets for exploitation. What makes this exploitation even more egregious, with their working days behind them, seniors can’t bounce back from fraudulent attacks to their portfolio.
One of the first things you can do to help protect your clients is to notice a diminished capacity. Tom, as Mrs. Robinson’s adviser, should automatically pick up that there is something off with her behavior. When an adviser sees a change in behavior, he or she should document this in the client’s records. If there’s a next of kin or a trusted contact person noted in your client’s file, it might be time to reach out to them to voice your concerns.
These are some of the first steps in handling those concerns. Over the next several weeks, we will cover various topic addressing senior vulnerability and financial exploitation including how to prevent it, how to identify it, and how to address it.
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