Financial Exploitation of Specified Adults

What this video covers

• Who qualifies as a "specified adult" under FINRA's rule: customers age 65 or older, and customers age 18 or older with a mental or physical impairment that prevents them from protecting their own interests
• What a trusted contact person (TCP) is, and the critical exam distinction that a TCP has zero trading authority and zero account access (versus an authorized party with power of attorney)
• Why firms must make "reasonable efforts" to obtain a TCP but cannot refuse to open an account if the customer declines to name one
• When a firm can place a temporary hold: the "reasonable belief" standard for suspected financial exploitation, and why the hold is limited to the specific suspicious activity (not the whole account)
• Why the 2022 amendment expanded holds to cover both disbursements and securities transactions, and why the old "disbursements only" framing is now a distractor
• The hold timeline math: 15 business days initial, plus 10 more (25 total) once reported to a state agency, plus 30 more (55 total) after reporting to a state regulator, agency, or court of competent jurisdiction
• The firm's notification and recordkeeping duties when placing a hold, including immediate notice to the TCP and all parties authorized to transact