Senior and vulnerable investors
Vulnerable client protection. The senior investor desk: exploitation indicators on specified adults, trusted contacts, holds on disbursements.
Agent read or preparedYou decide or sendClient said or holds
I read 7 accounts for Margaret Ellison against 1 rule. I raised 3 findings, and prepared 4 actions; 4 still wait on you.
Watch every specified adult's account for the indicators the rule names, and prepare the hold and the callback a person makes.
- Reads
- Every household's accounts, positions and file
- Checks
- Possible diminished capacity or financial exploitation
- Prepares
- a hold until a principal decides; a callback on a number on file; a form request; a task with an owner
- Runs
- Every morning
- Never
- Never sends, never clears its own finding, and no advisor can switch it off or loosen it without a principal.
- How
- 1 rule, each a stated condition over facts computed from the book; under a rule's confidence floor, or without the source it needs, it asks a person rather than clears.
- Built on
- FINRA Rule 2165, Financial Exploitation of Specified Adults; FINRA Rule 4512, Customer Account Information
Rules this desk watches (1)
Each rule is data: a stated condition over facts computed from the book, the settings a layer may tighten, what the desk prepares when it fires, and the text it is built on with where that text stands in law today.
Possible diminished capacity or financial exploitation
- Fires when
- the client's age is at least 65 and a disbursement is unusual or a new third party is in contact or not: a trusted contact is on file
- Settings
- Specified adult age: 65 (bounds 18 to 90, stricter is lower)
- Prepares
- a hold until a principal decides; a callback on a number on file; a form request; a task with an owner
- Needs
- Custodian positions and trades, Salesforce Financial Services Cloud
- In law
- In force since February 5, 2018, together with the trusted contact requirement in Rule 4512.
- Source
- FINRA Rule 2165, Financial Exploitation of Specified Adults; FINRA Rule 4512, Customer Account Information
- Today
- Raised 3 for Margaret Ellison.
Findings it raised (3)
Tune this desk for Margaret Ellison
Editing asA lower layer can only tighten; a refused change stays in the log.
AgentSenior and vulnerable investors
Daily. 1 rule, 1 evaluable with what is connected.
Why the desks are data, and what an advisor layer may change
Teach this desk a policy
Paste or drop a written supervisory procedure. The reader turns each sentence that carries an obligation into a candidate rule in the same shape the engine runs, cited to the sentence. You add the ones that say what the firm meant; each is in force on the next sweep and lands in the change log in your name.
What the reader does
- Keeps only sentences with an obligation: must, may not, is required.
- Matches the facts the engines compute, by the words a policy uses for them.
- Reads the number and the comparator beside each fact.
- Takes severity from the verb: a prohibition blocks, a review flags.
- Cites the rule the sentence cites, or the paragraph.