ELDER JUSTICE

National Strategy 

Needed to Effectively 

Combat Elder 

Financial Exploitation

Report to Congressional Requesters

November 2012

GAO-13-110

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-110, a report to 

congressional requesters

November 2012

ELDER JUSTICE

National Strategy Needed to Effectively Combat 

Elder Financial Exploitation

Why GAO Did This Study

Elder financial exploitation is the illegal 

or improper use of an older adult’s 

funds or property. It has been 

described as an epidemic with societywide repercussions. While combating 

elder financial exploitation is largely the 

responsibility of state and local social 

service, criminal justice, and consumer 

protection agencies, the federal 

government has a role to play in this 

area as well. GAO was asked to review 

issues related to elder financial 

exploitation. This report describes the 

challenges states face in (1) preventing 

and (2) responding to elder financial 

exploitation, as well as the actions 

some federal agencies have taken to 

help states address these challenges. 

To obtain this information, GAO 

interviewed state and local social 

service, criminal justice, and consumer 

protection officials in California, Illinois, 

New York, and Pennsylvania—states 

with large elderly populations; officials 

in seven federal agencies; and various 

elder abuse experts. GAO also 

analyzed federal strategic plans and 

other documents and reviewed 

relevant research, federal laws and 

regulations, and state laws. 

What GAO Recommends

Federal agencies should develop a 

written national strategy addressing 

challenges GAO identified, facilitate 

case investigation and prosecution, 

and improve data, among other things.

The Consumer Financial Protection 

Bureau and the Department of Health 

and Human Services supported GAO’s 

recommendations. FTC did not believe 

it is necessary to examine the 

feasibility of requiring victim’s age in 

complaints. GAO maintains the 

importance of its recommendation.

What GAO Found

Officials in each of the four states GAO contacted identified the need for more 

safeguards and public awareness activities to help prevent elder financial 

exploitation. They also noted that it is difficult to prevent exploitation by 

individuals such as financial services providers, power of attorney agents, 

guardians, and paid in-home caregivers. Although states have primary 

responsibility for combating elder financial exploitation, the federal government 

could disseminate information on model power of attorney legislation, for 

example, to help states better safeguard against power of attorney abuse—one 

type of federal activity authorized under the Older Americans Act of 1965. In 

addition, experts and state and local officials told GAO that many older adults

need more information about what constitutes elder financial exploitation in order 

to report and avoid it. The seven federal agencies GAO reviewed have 

undertaken activities to increase public awareness of elder financial exploitation. 

While some experts observed that a nationwide approach to educating the public 

is needed, federal public awareness activities are not currently conducted as part 

of a broader coordinated approach, which GAO believes could help ensure the 

effective use of federal resources. The Elder Justice Coordinating Council, which 

held its first meeting in 2012, could be the vehicle for developing and 

implementing a coordinated national strategy. The Council is composed of 

officials from federal agencies and is charged with developing national priorities 

and coordinating federal elder justice activities.

Experts and officials in each state GAO reviewed indicated that difficulty 1) 

gaining expertise, 2) sustaining collaboration between law enforcement and adult 

protective services agencies, and 3) obtaining data hinders their response to 

elder financial exploitation. As with prevention, many federal agencies have 

individually taken steps to address these challenges that are in line with their own 

missions. For example, the Department of Justice (Justice) has begun to 

construct a website that contains training and other materials prosecutors can 

use to build their expertise in investigating and prosecuting elder abuse, which 

includes elder financial exploitation. However, there are gaps in federal support 

in some areas. For example, law enforcement officials in each of the four states 

GAO reviewed indicated that it is not clear how they should obtain the federal 

support they need to respond to interstate and international cases. Justice can 

provide this information, in keeping with its priority to strengthen its relationship 

with state and local law enforcement. Similarly, the Federal Trade Commission’s

(FTC) Consumer Sentinel Network database compiles incidents of financial 

exploitation reported to it by many sources around the country but receives 

incidents from state government agencies in only 12 states. The database would 

be of greater use if FTC obtained incidents from more of the states and 

contained an indicator that the incident involved an older adult. 

View GAO-13-110. For more information, 

contact Kay Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-13-110 Elder Financial Exploitation

Letter 1 

Background 4

States Identified the Need for More Safeguards and Public 

Awareness Activities to Prevent Elder Financial Exploitation 12

Difficulty Gaining Expertise, Sustaining Collaboration, and 

Obtaining Data Hinders States’ Responses to Elder Financial 

Exploitation 22

Conclusions 38

Recommendations for Executive Action 39

Response to Agency Comments 41

Appendix I Administration on Aging 44

Appendix II Consumer Financial Protection Bureau 45

Appendix III Federal Trade Commission 46

Appendix IV Financial Crimes Enforcement Network 47

Appendix V Department of Justice 48

Appendix VI Federal Bureau of Investigation 49

Appendix VII U.S. Attorneys 50

Appendix VIII U.S. Postal Inspection Service 51

Contents 
Page ii GAO-13-110 Elder Financial Exploitation

Appendix IX Securities and Exchange Commission 52

Appendix X Examples of State and Local Activities to Prevent and 

Respond to Elder Financial Exploitation 53

Appendix XI Examples of Non-Governmental Organization Activities to 

Prevent and Respond to Elder Financial Exploitation 58

Appendix XII Criminal Background Check Requirements for In-home 

Caregivers in Selected States 63

Appendix XIII Resource Centers Supported by the Administration on Aging 64

Appendix XIV Example of a Letter Promoting a Fraudulent Sweepstakes 

Scheme 65

Appendix XV Total Number of FTC Consumer Sentinel Network 

Complaints by Source, CY 2011 66

Appendix XVI Comments from the Consumer Financial Protection Bureau 67

Appendix XVII Comments from the Department of Health and Human 

Services 70

Appendix XVIII GAO Contacts and Staff Acknowledgements 72
Page iii GAO-13-110 Elder Financial Exploitation

Related GAO Products 73

Tables

Table 1: Examples of Forms of Elder Financial Exploitation by 

Type of Perpetrator 4

Table 2: Selected Public Awareness Efforts of Federal Agencies 

Related to Elder Financial Exploitation 21

Table 3: Examples of AoA and Justice Resources That Could Be 

Used to Increase State and Local Expertise about Elder 

Financial Exploitation 24

Table 4: Examples of Federal Grants That Encourage Collaboration 

among State Agencies That Respond to Elder Abuse 27

Table 5: Federal Administrative Data Systems That Collect 

Incidents of Elder Financial Exploitation 36

Figures

Figure 1: State and Federal Systems and Agencies Positioned to 

Combat Elder Financial Exploitationa 6

Figure 2: Federal Agencies with Missions That Involve Combating 

Elder Financial Exploitation 8

Figure 3: Federal Agencies’ Responsibilities in Combating 

International and Interstate Financial Crimes 30
Page iv GAO-13-110 Elder Financial Exploitation

Abbreviations

AoA Administration on Aging 

APS Adult protective services 

CFPB Bureau of Consumer Financial Protection 

 (commonly referred to as the Consumer Financial 

 Protection Bureau) 

CDAA California District Attorneys Association 

Consumer Sentinel Consumer Sentinel Network database 

HHS Department of Health and Human Services 

Justice Department of Justice 

EFPN Elder Financial Protection Network 

EJA Elder Justice Act of 2009

EJCC Elder Justice Coordinating Council 

FTC Federal Trade Commission

FinCEN Financial Crimes Enforcement Network 

FINRA Financial Industry Regulatory Authority 

NASAA North American Securities Administrators 

NCEA National Center on Elder Abuse 

Office for Older Office for the Financial Protection of Older 

 Americans Americans

OAA Older Americans Act of 1965

RFPA Right to Financial Privacy Act of 1978 

SEC Securities and Exchange Commission 

SAR Suspicious Activity Report

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Page 1 GAO-13-110 Elder Financial Exploitation

United States Government Accountability Office

Washington, DC 20548

November 15, 2012

Congressional Requesters

Elder financial exploitation is the illegal or improper use of an older adult’s 

funds, property, or assets.1

Elder financial exploitation has far-reaching effects on its victims in 

particular and society in general. A study of media reports from April to 

June 2010 estimated that financial exploitation cost older adults at least 

$2.9 billion in 2010.

Experts have described it as an epidemic with 

society-wide repercussions. Perpetrators may be family members; paid 

home care workers; those with fiduciary responsibilities, such as financial 

advisors or legal guardians; or strangers who inundate older adults with 

mail, telephone, or Internet scams. Older adults are particularly 

vulnerable to financial exploitation because, as research has shown, 

financial decision-making ability decreases with age. Moreover, older 

adults are often ashamed to report exploitation or even admit that they 

have been exploited because they are afraid of losing their 

independence. As a result, existing data on elder financial exploitation 

may substantially underestimate its extent.

2 The money that older adults lose in these cases is 

rarely recovered, and the loss can undermine both the health of older 

adults and their ability to support or care for themselves. Consequently, 

the burden of caring for exploited older adults may fall on various state 

and federal programs. For example, a review of 80 elder financial 

exploitation cases in Utah in 2010 found the state’s Medicaid program 

would potentially have to pay about $900,000 to cover the cost of care for 

older adults in that state who had suffered substantial losses.3

 

1 See GAO, Elder Justice: Stronger Federal Leadership Could Enhance National 

Response to Elder Abuse, GAO-11-208 (Washington, D.C.: March 2, 2011).

2 MetLife Mature Market Institute et. al., The MetLife Study of Elder Financial Abuse: 

Crimes of Occasion, Desperation, and Predation against America’s Elders (2011). The 

study assumed that the approximately $530 million in loss from all forms of elder financial 

abuse occurred at the same rate for the other 9 months of the year. It further assumed 

that this loss would be the same for the 36 percent of articles about elder financial abuse 

that the study identified but did not cite a specific dollar figure for.

3 Gunther, Jilenne, The 2010 Utah Cost of Financial Exploitation, Utah Division of Aging 

and Adult Services (2012).

 
 

Page 2 GAO-13-110 Elder Financial Exploitation

As the U.S. population ages, growing numbers of older adults could be at 

risk of financial exploitation, so its potential impact on society is likely to 

increase. Combating elder financial exploitation is primarily the 

responsibility of state and local agencies. At the same time, however, 

multiple federal agencies have a role to play in supporting state and local 

efforts. In light of these growing concerns, we were asked to provide 

information on elder financial exploitation issues. Specifically, this report 

addresses the challenges states face in (1) preventing and (2) responding 

to elder financial exploitation, as well as the actions some federal 

agencies have taken to help states address these challenges.

To address these objectives, we interviewed officials from agencies that 

included state and local social services, criminal justice, and consumer 

protection agencies in California, Illinois, New York, and Pennsylvania. 

We selected these states to achieve variation in location, because of the 

large size of their elder population, and because each state had a number 

of initiatives to combat elder financial exploitation. Across the four states, 

we held interviews with representatives from entities such as state and 

local adult protective services (APS) agencies; offices of attorneys 

general; police and sheriffs’ departments; local district attorneys and 

courts; and state banking, securities, and insurance regulators. In three of 

the four states we also spoke with private organizations that work on 

issues related to elder financial exploitation, such as a university research 

center, elder abuse forensic center, and state banking association. In 

Pennsylvania, we met with experts from the Institute on Protective 

Services at Temple University and also attended an elder financial 

exploitation training for APS workers that was hosted by the Institute. We 

focused only on financial exploitation of older adults living at home, not on 

older adults in long-term care facilities.

We also interviewed experts in the field of elder abuse—including 

academics and practitioners—and representatives from a variety of nonprofit and private sector organizations, such as the AARP, American Bar 

Association, and American Bankers Association. We interviewed 

representatives from University of California at Irvine’s Center of 

Excellence on Elder Abuse and Neglect and the University of Kentucky’s 

Justice Center for Elders and Vulnerable Adults. In addition, in order to 

gain the perspectives of large national and small community banks, we 

interviewed officials at six financial institutions. These banks are not, 

however, representative of banks nationwide.

Furthermore, we interviewed officials and analyzed strategic plans and 

other documents from seven federal agencies—including the 
 

Page 3 GAO-13-110 Elder Financial Exploitation

Administration on Aging (AoA) within the Department of Health and 

Human Services (HHS), Bureau of Consumer Financial Protection 

(commonly referred to as the Consumer Financial Protection Bureau or 

CFPB), Department of Justice (Justice), Federal Trade Commission 

(FTC), Financial Crimes Enforcement Network (FinCEN) within the 

Department of the Treasury, Postal Inspection Service, and Securities 

and Exchange Commission (SEC). In total, we held dozens of interviews 

with experts and officials from federal, state, local, and non-governmental 

organizations.

We also reviewed relevant federal laws and regulations, as well as 

selected state laws. Moreover, we attended the initial meeting of 

members of the Elder Justice Coordinating Council (EJCC), which 

includes officials from 11 federal agencies with an interest in elder abuse. 

We also attended several conferences related to elder financial 

exploitation, including the American Society on Aging’s 2012 Aging in 

America Conference, California District Attorneys Association’s (CDAA) 

2011 Elder Abuse Symposium, Stanford Center on Longevity and the 

Financial Industry Regulatory Authority’s (FINRA) 2011 State and Future 

of Financial Fraud Conference, Elder Financial Protection Network’s 

(EFPN) 2012 Call to Action Conference, and a 2011 webcast on elder 

issues hosted by the Nebraska Department of Health and Human 

Services and State Bar Association’s 2011 Elder Issues Webcast. At the 

CDAA Symposium, we held small group meetings with district attorneys 

and investigators from various counties in California. And at the EFPN 

Conference we held a small group meeting with local district attorneys, 

advocates, a state insurance agency official, and a financial institution.

To illustrate the complexities of combating elder exploitation, we met with 

a social service agency, several criminal justice agencies, and, in one 

case, a family member to develop detailed case histories on six 

prosecuted cases of elder financial exploitation. The perpetrators in these 

cases were family members, financial services providers, or telephone 

scammers. We identified cases from news stories and internet searches. 

We selected six cases because they (1) occurred in three of our four 

review states (California, New York, and Pennsylvania), (2) involved each 

of the different types of elder financial exploitation (exploitation by family 

or trusted others, exploitation by financial services providers, and

exploitation by strangers), and (3) included instances where more than 

one agency or system was involved. The cases we selected are a nongeneralizable sample of elder financial exploitation cases. 
 

Page 4 GAO-13-110 Elder Financial Exploitation

Lastly, we identified and reviewed research published from 2000 onward 

on elder financial abuse or elder financial exploitation by searching 

numerous bibliographic databases and reviewing materials cited by elder 

abuse experts or published by federal, state, and non-governmental 

organizations. We focused our review on published research on the 

extent, impact, cost, and nature of elder financial exploitation. We also 

interviewed an official from the Utah Division of Aging and Adult Services 

to discuss the state’s study on the cost of elder financial exploitation.

We conducted this performance audit from November 2011 to November 

2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. Our investigative activities 

were conducted in accordance with standards prescribed by the Council 

of the Inspectors General for Integrity and Efficiency.

Elder financial exploitation, one type of elder abuse, can occur in 

conjunction with, and might lead to other types of elder abuse.4

Table 1: Examples of Forms of Elder Financial Exploitation by Type of Perpetrator 

Financial 

exploitation of older adults can take many forms and perpetrators can 

include family members, friends, legal guardians, paid caregivers, and 

strangers. Table 1 provides some examples.

Perpetrators Forms 

Family members, friends, in-home caregivers, 

legal guardians, representative payeesa

, etc.

—Theft of cash or other valuables

—Withdrawals from bank accounts or use of credit cards

—Transfer of deeds

—Misuse of an older adult’s power of attorney

—Misappropriation of an incapacitated older adult’s income or assets

—Identity theft

 

4 Other types of elder abuse include physical, psychological, and sexual abuse, as well as 

neglect and self-neglect.

Background 
 

Page 5 GAO-13-110 Elder Financial Exploitation

Perpetrators Forms 

Financial services providers (brokers, 

financial advisors, insurance agents, or 

others in the financial services industry) 

—Sale of fraudulent investments (Ponzi or pyramid schemes)

—Sale of financial products or services unsuitable for an older adult’s 

circumstances, such as long-term annuities 

Strangers —Lottery, mail, telephone, or Internet scams

—Door-to-door home repair scams

—Identity theft

Source: GAO analysis of published research. 

a

Representative payees are persons who receive Social Security benefits on behalf of recipients who 

are determined to be incapable of managing their finances. 20 C.F.R. §§ 416.601 and 416.2001.

Older adults are particularly attractive targets for financial exploitation by 

unscrupulous individuals. As a group, older adults tend to possess more 

wealth than those who are younger because they have had a longer time 

to acquire it. In addition, the incidence of Alzheimer’s disease and other 

dementias that undermine judgment increases with age.5 Moreover, 

financial capacity—the capacity to manage money and financial assets in 

ways that meet one’s needs—generally declines with age, and this 

decline may go unaddressed until it is too late.6

State and local agencies in the social services, criminal justice, and 

consumer protection systems in each state are at the forefront of efforts 

to prevent, detect, and respond to elder financial exploitation. Seven 

federal agencies whose missions correspond to the state and local social 

service, criminal justice, and consumer protection systems are positioned 

to contribute to state and local efforts in this area: AoA, CFPB, Justice, 

FTC, FinCEN, SEC, and the Postal Inspection Service (see fig. 1).7

 

5 Hebert et al., “Alzheimer Disease in the US Population,” Archives of Neurology, 60 

(August 2003): 1119-1122. 

6 Agarwal et al., “The Age of Reason: Financial Decisions over the Life Cycle with 

Implications for Regulation,” Brookings Papers on Economic Activity 2 (Washington, D.C.: 

2009): 51-117.

7

 See appendixes I through IX for additional information on each of these agencies. The 

Department of Housing and Urban Development (HUD) also functions as a federal 

consumer protection agency in that they administer the Home Equity Conversion 

Mortgage Program, the nation’s largest reverse mortgage program for older adults. 
 

Page 6 GAO-13-110 Elder Financial Exploitation

Figure 1: State and Federal Systems and Agencies Positioned to Combat Elder Financial Exploitationa

a The relationship between the federal and the state and local agencies in a given system varies.

b State attorneys general also play a consumer protection role.

c Justice also plays a consumer protection role.
 

Page 7 GAO-13-110 Elder Financial Exploitation

At the state and local level, APS agencies investigate and substantiate 

reports of suspected elder abuse, including financial exploitation and, if 

the client agrees to accept help, can arrange for services to secure their 

safety and meet their basic needs. APS can also refer cases to law 

enforcement agencies or district attorneys for criminal investigation and 

prosecution. Whether an elder financial exploitation case comes to the 

attention of criminal justice authorities through referral from APS or some 

other means, law enforcement agencies and district attorneys can 

exercise broad discretion when deciding if a case warrants any action on 

their part.

State-level consumer protection agencies—such as banking, securities, 

and insurance regulators—conduct examinations to ensure that rules to 

protect consumers are followed and take enforcement actions against 

institutions that break the rules. State attorneys general may also 

prosecute cases or respond to consumer protection inquiries.

Although combating elder financial abuse is explicitly included in the 

mission of only one federal agency, CFPB’s Office for the Financial 

Protection of Older Americans (Office for Older Americans), it is implicit in 

the mission of others that work to combat elder abuse, protect consumers 

or investors, or prevent fraud (see fig. 2).
 

Page 8 GAO-13-110 Elder Financial Exploitation

Figure 2: Federal Agencies with Missions That Involve Combating Elder Financial Exploitation

a

Justice also plays a consumer protection role. Specifically, two of Justice’s strategic objectives are to 

(1) prevent and intervene in crimes against vulnerable populations; uphold the rights of, and improve 

services to, America’s crime victims; and (2) combat corruption, economic crimes, and international 

organized crime.

Federal legislation has established a foundation for the federal 

government to assume a leadership role in combating elder abuse, 

including elder financial exploitation, and basis for greater coordination 
 

Page 9 GAO-13-110 Elder Financial Exploitation

across federal agencies in this area. The Older Americans Act of 1965 

(OAA)8

• facilitating the development, implementation, and continuous 

improvement of a coordinated, multidisciplinary elder justice system in 

the United States;

requires AoA to develop objectives, priorities, policy, and a longterm plan for 

• promoting collaborative efforts and diminishing duplicative efforts in 

the development and carrying out of elder justice programs at the 

federal, state, and local levels;

• establishing an information clearinghouse to collect, maintain, and 

disseminate information concerning best practices and resources for 

training, technical assistance, and other activities to assist states and 

communities to carry out evidence-based programs to prevent and 

address elder abuse, neglect, and exploitation;

• working with states, Justice, and other federal agencies to annually 

collect, maintain, and disseminate data on elder abuse, neglect, and 

exploitation, to the extent practicable;

• establishing federal guidelines and disseminating best practices for 

uniform data collection and reporting by states;

• conducting research on elder abuse, neglect, and exploitation; and

• carrying out a study to determine the extent of elder abuse, neglect, 

and exploitation in all settings.9

The Elder Justice Act of 2009 (EJA)10

 

8 Pub. L. 89-73, 79 Stat. 218 (codified as amended at 42 U.S.C. §§ 3001-3058ff). 

contains provisions pertaining to 

APS as well as elder justice, in general. It authorizes funding for 

9 42 U.S.C. § 3011(e)(2). 

10 Pub. L. No. 111-148, tit. VI, subtit. H, 124 Stat. 119, 782-804 (2010) (codified at 42 

U.S.C. §§ 1320b-25, 1395i-3a, and 1397j-1397m-5). The EJA was enacted as part of the 

Patient Protection and Affordable Care Act, which was signed into law on March 23, 2010.
 

Page 10 GAO-13-110 Elder Financial Exploitation

• HHS to

o annually collect and disseminate data regarding elder abuse, 

neglect, and exploitation of elders in coordination with 

Justice;11

o develop and disseminate information on best practices and 

provide training for carrying out adult protective services;12

o conduct research related to the provision of adult protective 

services;13

o provide technical assistance to states and others that provide 

or fund the provision of adult protective services;14

o establish 10 elder abuse, neglect, and exploitation forensic 

centers, in consultation with Justice, that would (1) conduct 

research on forensic markers for elder abuse, neglect, or 

exploitation, and methodologies for determining when and how 

health care, emergency, social and protective, and legal 

service providers should intervene and when these cases 

should be reported to law enforcement; (2) develop forensic 

expertise regarding elder abuse, neglect, and exploitation; and 

(3) use the data they have collected to develop, in coordination 

with Justice, the capacity of geriatric health care professionals 

and law enforcement authorities to collect forensic evidence, 

including evidence needed to determine if elder abuse, 

neglect, or exploitation has occurred.

and 

15

 

11 § 2042(a)(1)(B) and (2), 124 Stat. 794 (codified at 42 U.S.C. § 1397m-1(a)(1)(B) and 

(2)). 

 

12 § 2042(a)(1)(C), 124 Stat. 794 (codified at 42 U.S.C. § 1397m-1(a)(1)(C)). 

13 § 2042(a)(1)(D), 124 Stat. 794 (codified at 42 U.S.C. § 1397m-1(a)(1)(D)). 

14 § 2042(a)(1)(E), 124 Stat. 794 (codified at 42 U.S.C. § 1397m-1(a)(1)(E)). 

15 § 2031, 124 Stat. 790-91 (codified at 42 U.S.C. § 1397l). 
 

Page 11 GAO-13-110 Elder Financial Exploitation

• Grants to state and local governments for demonstration projects that 

test methods and training to detect or prevent elder abuse or financial 

exploitation;16

• An Elder Justice Coordinating Council and an Advisory Board on 

Elder Abuse, Neglect, and Exploitation to develop priorities for the 

elder justice field, coordinate federal activities, and provide 

recommendations to Congress.

and

17

Currently, the Elder Justice Coordinating Council consists of the following 

federal agencies: Consumer Financial Protection Bureau, Corporation for 

National and Community Service,18

Coordination among federal agencies is also a feature of the Dodd-Frank 

Wall Street Reform and Consumer Protection Act, which established 

CFPB, requiring it to coordinate its consumer protection efforts of older 

adults with other federal agencies.

Department of Health and Human 

Services, Department of Housing and Urban Development, Department of 

Justice, Department of Labor, Department of the Treasury, Department of 

Veterans Affairs, Federal Trade Commission, Postal Inspection Service, 

and Social Security Administration. 

19 CFPB’s Office for Older Americans is 

charged with facilitating the financial literacy of seniors on protection from 

unfair, deceptive, and abusive practices and on current and future 

financial choices.20

 

16 § 2042(c), 124 Stat. 795 (codified at 42 U.S.C. 1397m-1(c)). 

17 §§ 2021 and 2022, 124 Stat. 786-89 (codified at 42 U.S.C. §§ 1397k and 1397k-1). 

18 The Corporation for National and Community Service is a federal agency that engages 

Americans in service through Senior Corps, AmeriCorps, and the Social Innovation Fund. 

42 U.S.C. § 12651.

19 Pub. L. No. 111-203, § 1015, 124 Stat. 1376, 1974 (2010) (codified at 12 U.S.C. § 

5495).

20 § 1013(g)(1), 124 Stat. 1973 (codified at 12 U.S.C. § 5493(g)(1)).
 

Page 12 GAO-13-110 Elder Financial Exploitation

According to officials in the four states we visited, financial exploitation of 

older adults by financial services providers, power of attorney agents, and 

in-home caregivers is particularly difficult to prevent.21

Older adults may consult with a variety of financial professionals, such as 

financial planners,22 broker-dealers,23 and insurance agents.24

 

21 See appendix X for examples of activities undertaken by APS, criminal justice, and 

consumer protection agencies in California, Illinois, New York, and Pennsylvania to 

prevent elder financial exploitation by financial services providers, power of attorney 

agents, and in-home caregivers. See appendix XI for examples of these activities 

undertaken by private organizations.

However, 

22 Financial planners can provide a variety of services, including preparing financial plans 

for clients based on their financial circumstances and objectives and making 

recommendations for specific actions clients may take. In many cases, financial planners 

also help implement these recommendations by, for example, selling investment products, 

such as insurance, securities, or other investments. Financial planners are subject to 

federal and state regulation pertaining to investment advisers, broker-dealers, and 

insurance agents, depending on the services they provide. See GAO, Consumer Finance: 

Regulatory Coverage Generally Exists for Financial Planners, but Consumer Protection 

Issues Remain, GAO-11-235 (Washington, D.C.: January 18, 2011).

23 Broker-dealers handle trades between the buyers and sellers of securities and charge a 

fee to do so. Broker-dealers may buy securities from customers or sell from their own 

inventory. Most are also members of the Financial Industry Regulatory Authority (FINRA). 

FINRA is a self-regulatory organization with oversight of all broker-dealers doing business 

with the public in the United States. 

24 Insurance agents sell products, such as life insurance or annuities. They must be 

licensed by the states to sell these products and are subject to state insurance regulation. 

The sale of variable insurance products, such as variable life insurance or variable 

annuities, is subject to both state insurance regulation and broker-dealer regulation. See 

GAO-11-235. 

States Identified the 

Need for More 

Safeguards and Public 

Awareness Activities 

to Prevent Elder 

Financial Exploitation

States Cited Need for More 

Safeguards to Prevent 

Elder Financial 

Exploitation 

Financial Services Providers 
 

Page 13 GAO-13-110 Elder Financial Exploitation

older adults, similar to other consumers, may lack the information to make 

sound decisions about choosing a financial services provider and 

protecting their assets from exploitation. As a result, they may 

unknowingly put themselves at risk of financial exploitation.

Individuals who present themselves as financial planners may adopt a 

variety of titles and designations. In some cases, privately conferred 

designations—such as Certified Financial Planner®—require formal 

certification procedures, including examinations and continuing 

professional education credits, while other designations may merely 

signify that membership dues have been paid. Designations that imply 

expertise in advising older adults have been a source of particular 

concern among state securities regulators, according to the North 

American Securities Administrators Association (NASAA).25 Older adults 

may lack information to distinguish among the various senior specific 

designations. Indeed, in 2011, we reported that there is some confusion 

about what these titles mean and the level of skill required to obtain 

them.26

Another concern is that older adults may be fooled by investment 

professionals who use questionable tactics to market financial products, 

 

25 NASAA is a national membership organization for state securities regulators. 

26 See GAO-11-235. 

Exploitation by “Senior Specialist”

Calling himself a senior financial advisor, an insurance agent licensed in California met 

an 89-year-old partially blind, intermittently confused man at a senior center. The 

agent persuaded him to invest about $250,000 in a flexible premium deferred annuity, 

warning him not to let anyone talk him out of it. As a result, the man was left with no 

penalty-free access to his entire life savings for the next 11 years, while the agent 

earned a commission on this transaction. To earn about $16,000 more in 

commissions, the agent then convinced the man to move half the amount invested in 

the annuity into unregistered stock, which cost the man a surrender fee of about 

$10,000. The stock turned out to be worthless, leaving the man with a fraction of what 

he had when he met the agent. Attempts by the man’s nephew to retrieve his uncle’s 

money were unsuccessful. The nephew reported the insurance agent to the California 

Department of Insurance, which eventually revoked the agent’s license, but local 

police did not pursue the older adult’s case. While the insurance agent faced no 

criminal charges in this case, he was later sentenced to 3 years in prison for 

defrauding another older adult.
 

Page 14 GAO-13-110 Elder Financial Exploitation

such as “free lunch seminars” at which financial professionals seek to sell 

financial products to older adults during a free meal. SEC, the Financial 

Industry Regulatory Authority (FINRA), and NASAA examined 110 firms 

that sponsored free lunch seminars from April 2006 to June 2007 offered 

in seven states and found that 63 seminars used misleading advertising 

and sales materials, 25 seminars resulted in unsuitable 

recommendations, and in 14 seminars there were fraudulent practices 

used, such as selling fictitious investments.27

Preventing the sale of unsuitable or fraudulent investments to older adults 

is difficult.28 An investment can be unsuitable for an older adult if it has 

features that might not provide its intended benefit during the investor’s 

lifetime. Older adults also can be sold what they believe to be legitimate 

investments, but are actually completely fraudulent products that hold 

little or no value.

SEC has developed some educational materials and SEC and CFPB 

have conducted research related to investment fraud that targets older 

adults. For example, SEC has published a guide for older adults that 

counsels them to check their investment adviser’s disciplinary history, 

lists warning signs of fraud, and provides information on where to go for 

 

27 SEC, FINRA, and NASAA, Protecting Senior Investors: Report on Examinations of 

Securities Firms Providing “Free Lunch” Sales Seminars (2007).

28 SEC, Guide for Seniors: Protect Yourself Against Investment Fraud; SEC, FINRA, and 

NASAA, Investor Alert, Investment Products and Sales Practices Commonly Used to 

Defraud Seniors: Stories from the Frontline. 

Investment Fraud Using a “Ponzi” Scheme

The founder and president of a real estate and financial consulting firm convinced 

around 200 individuals—about one-third of whom were older adults—to invest in real 

estate projects that failed to generate any significant revenue. He also convinced them 

to obtain reverse mortgages on their homes, and to invest the proceeds with his firm. 

The investments turned out to be a “Ponzi” scheme. Specifically, the perpetrator paid 

distributions to some investors from others’ deposits; misled investors with false 

amortization schedules; and used investors’ money to pay for his Porsche, mortgage, 

and other personal expenses. The scheme was reported to FINRA, investigated by the 

FBI, and prosecuted by the Eastern District of New York U.S. Attorney’s Office, which 

sought sentencing enhancements for targeting the elderly. Victims lost over $12 

million. They also reported irreplaceable financial losses, emotional distress, feelings 

of betrayal and disbelief, and various physical symptoms as a result. 
 

Page 15 GAO-13-110 Elder Financial Exploitation

help.29 SEC also provides a link to a FINRA website that provides 

consumers with the required qualifications, including educational 

requirements, of the designations used by securities professionals. In 

August 2012, SEC released a study on financial literacy among investors 

and stated the agency’s desire to develop a strategy for increasing the 

financial literacy of certain groups, including older adults. CFPB plans to 

issue a report in early 2013 to Congress and the SEC that will address 

providing information to older adults about financial advisors and their 

credentials. In June 2012, the CFPB issued a public inquiry for 

information about elder financial exploitation, including a question on what 

resources older adults have to determine the legitimacy, value, and 

authenticity of credentials held by investment professionals.30

Older adults can use a legal document referred to as a financial power of 

attorney to appoint another person (an agent) to manage their finances 

should they become incapable of doing so. Having a financial power of 

attorney enables an older adult (a principal) to choose the person who 

can legally make these decisions for them, when needed. Powers of 

attorney are easy for anyone to create, can vary in specificity and format, 

and do not require legal assistance or a court for execution. Each of the 

four states we contacted has a law that helps prevent misuse of powers 

of attorney by specifying the responsibilities of agents and, in at least one, 

penalties for misuse. However, powers of attorney can be forged or 

perhaps otherwise improperly obtained without a principal’s knowledge or 

consent and an agent can easily use the principal’s money for his or her 

own benefit. For this reason, many state and local officials we interviewed 

in the four states were concerned about misuse of these instruments. For 

example, one Pennsylvania official described power of attorney 

documents as a “powerful, simple, and dangerous tool.” 

CFPB 

expects to share its results in 2013.

 

29 SEC, Guide for Seniors: Protect Yourself Against Investment Fraud. 

30 CFPB, “Request for Information Regarding Senior Financial Exploitation,” 77 Fed. Reg. 

36,491 (June 19, 2012).

Power of Attorney
 

Page 16 GAO-13-110 Elder Financial Exploitation

Some APS and criminal justice officials we spoke to indicated that 

stronger state power of attorney laws could help prevent elder financial 

exploitation by agents. For example, Pennsylvania officials said that 

current state laws have been ineffective at (1) creating practices to 

monitor the activities of power of attorney agents and (2) encouraging 

banks to question power of attorney documents they find questionable. In 

California, law enforcement officials noted that notaries were not always 

held accountable for their role in signing power of attorney documents.

To help strengthen state laws designed to prevent misuse of financial 

powers of attorney, the Uniform Law Commission31

• explicitly defines the duties of the power of attorney agent, 

including fiduciary duties such as acting in good faith and keeping 

careful records;

has developed the 

Uniform Power of Attorney Act, which

• allows a third party to refuse to honor a power of attorney 

agreement if there is a good faith belief that the principal may be 

subject to abuse, and requires the third party to report to APS;

• allows co-agents to be appointed for additional third-party 

oversight; and

• imposes liability on agents who violate the law.

 

31 The Uniform Law Commission is a state-supported organization that drafts model 

legislation to promote clarity and stability to critical areas of state statutory law. 

Power of Attorney Abuse

A month after an elderly man with dementia and his wife agreed to add their 

daughter’s name to their bank account, the daughter convinced her mother to sign a 

document providing her financial power of attorney. When the woman signed, she 

was in the hospital for a broken hip and a stroke and later claimed she was heavily 

medicated. Over the next 3 months, the daughter placed the deed to her parent’s 

home in her name, wrote checks on their account totaling nearly $600,000 that were 

never questioned by the bank, and attempted to withdraw about $500,000 more. 

When the woman’s son discovered what had been happening, he had the bank stop 

payment on the $500,000 and asked the local district attorney to investigate. The 

daughter was charged with numerous counts of theft, pled guilty, and was sentenced 

to 3 years probation. The deed was transferred back to the woman and although the 

prosecutor sought restitution, the $600,000 was not recoverable—it had been used to 

pay off the daughter’s mortgage, country club membership, and other bills.
 

Page 17 GAO-13-110 Elder Financial Exploitation

According to the Uniform Law Commission, 13 states have adopted the 

entire Uniform Power of Attorney Act.32

Powers of attorney are generally regulated under state, not federal, law; 

however, AoA and CFPB are providing some information to states and 

power of attorney agents to help prevent power of attorney abuse. The 

AoA-supported National Legal Resource Center co-sponsors trainings for 

states on the adoption of the Uniform Power of Attorney Act. Furthermore, 

the CFPB is developing a guide to educate “lay fiduciaries”—including 

guardians and agents under powers of attorney—about their 

responsibilities, and is planning to develop several state-specific lay 

fiduciary guides, scheduled for release in 2013.

Others have enacted various 

other power of attorney laws. For example, New York requires an agent 

to provide a full accounting to APS when it is investigating a report that 

the principal may be in need of protective or other services or the victim of 

abuse or neglect. If it is not provided within 15 days, APS can commence 

a special proceeding to compel the production of the information. Illinois 

has added safeguards for principals to its law and created additional court 

remedies for violations of the law. However, according to the Uniform Law 

Commission, a number of states have made no changes to laws 

governing powers of attorney since the Uniform Power of Attorney Act 

was published.

There are limited safeguards to protect older adults from abuse by 

guardians, who are granted authority by a state court to make decisions 

in the best interest of an incapacitated individual concerning his or her 

person or property. While guardians can play a key role in managing the 

assets of these older adults, we have noted in past reports that guardians 

are only subject to limited safeguards that could protect these older adults 

from financial exploitation. For example, local officials in California noted 

that it can be hard to determine whether a person applying to be a 

guardian is doing so to further his ward’s best interests. We have also 

reported that few states conduct criminal background checks on potential 

guardians. Moreover, we have noted concerns with weak court oversight 

of appointed guardians, as well as poor communication between the 

 

32 According to the Uniform Law Commission, Alabama, Arkansas, Colorado, Idaho, 

Maine, Montana, Nebraska, Nevada, New Mexico, Ohio, Virginia, West Virginia, and 

Wisconsin have adopted the Uniform Power of Attorney Act. 

Guardians
 

Page 18 GAO-13-110 Elder Financial Exploitation

courts and federal agencies that have enabled guardians to chronically 

abuse their wards and/or others.33

Exploitation by in-home caregivers was also cited by local APS officials, 

police, and district attorneys we spoke to as a type of abuse that is 

difficult to prevent. These caregivers range from personal care aides who 

provide non-medical assistance such as helping with laundry and 

cooking, to home health aides who check an older adult’s vital signs or 

assist with medical equipment. In-home caregivers may be employed by 

a private company approved to provide services via a state’s OAA34

program or independently hired by older adults or their families. Caregiver 

services may also be covered under a state Medicaid program if the 

individual is eligible for Medicaid.35

Older adults may rely on and trust in-home caregivers, and some 

caregivers have used that relationship to exploit their clients.36

States are responsible for protecting older adults from exploitation by inhome caregivers, and safeguards vary by state. Police and district 

attorneys we interviewed were concerned that in-home caregivers are 

For 

example, a caregiver may be given access to an older adult’s ATM or 

credit card to help with banking or grocery shopping and later be found 

withdrawing money or purchasing items for themselves. As the population 

ages and public policies encourage older adults to remain in their homes 

for as long as practical, there will be an increased need for in-home 

caregivers.

 

33 See GAO, Guardianships: Cases of Financial Exploitation, Abuse, and Neglect of 

Seniors, GAO-10-1046 (Washington, D.C.: September 30, 2010), and GAO, Incapacitated 

Adults: Oversight of Federal Fiduciaries and Court-Appointed Guardians Needs 

Improvement, GAO-11-678 (Washington, D.C.: July 22, 2011). 

34 OAA Title III-B provides funding for in-home services, such as personal care, chore, 

and homemaker assistance. 

35 42 U.S.C. § 1396d(a)(7). Medicaid is a joint federal-state financing program for health 

care services for certain low-income individuals. State Medicaid programs may cover 

home-based care, such as personal care and homemaker services, for Medicaid 

beneficiaries who need help with self-care due to disabilities or health conditions. 

36 According to AoA, many of those who exploit older adults are informal or family 

caregivers who are not employed or subject to background checks and this may be a 

more difficult type of exploitation to prevent. 

Caregivers 
 

Page 19 GAO-13-110 Elder Financial Exploitation

subject to limited, if any, background checks. A California law 

enforcement official told us that caregivers suspected of exploiting older 

adults sometimes have a history of theft. While the Medicaid program 

requires states to develop and implement home care provider 

qualification standards, there is no federal Medicaid requirement for 

criminal background checks.37 According to the National Conference of 

State Legislatures, while many states have required agencies to conduct 

background checks before employing in-home caregivers who are paid by 

Medicaid or with other state funds, these laws vary greatly in their breadth 

and scope and the amount of flexibility afforded the agencies when they 

use the checks to make hiring decisions.38 Napa County, California 

recently initiated an innovative paid in-home caregiver screening initiative. 

Before in-home caregivers can work in that county, they must submit to a 

background check and obtain a permit annually.39

While background checks for in-home caregivers help flag potential 

abusers, an AARP study has found that states do not always use all 

available federal, state, and local criminal data systems. For one, the 

implementation cost may discourage their use. Moreover, their 

effectiveness in reducing elder abuse, in general, is unproven.40 As 

required by the Patient Protection and Affordable Care Act of 2010,

41

 

37 States must enact standards for provider participation to ensure that providers are 

qualified, effective, and cost-efficient, and to protect program beneficiaries. At the same 

time, these requirements must not unfairly restrict participation in the Medicaid program. 

As long as states meet these criteria, they have significant latitude in specifying their 

provider qualification requirements. AARP Public Policy Institute, Safe at Home? 

Developing Effective Criminal Background Checks and Other Screening Policies for Home 

Care Workers (September 2010).

the 

Centers for Medicare and Medicaid Services implemented the National 

Background Check Program that encourages states to adopt safeguards 

to protect clients of in-home caregivers. This voluntary program provides 

grants to states to conduct background checks for employees of longterm care facilities and providers, such as home health agencies and 

38 National Conference of State Legislatures, State Policies on Criminal Background 

Checks for Medicaid-Supported In-Home Direct Care Workers (December 18, 2008).

39 See appendix XII for examples of background check requirements for in-home 

caregivers in the four states we reviewed. 

40 See AARP Public Policy Institute, Safe at Home?

41 Pub. L. No. 111-148, tit. VI, subtit. C, § 6201, 124 Stat. 119, 721.
 

Page 20 GAO-13-110 Elder Financial Exploitation

personal care service providers. As of November 2012, 19 states were 

participating. The results of this program could provide data on the 

effectiveness of background checks in preventing elder abuse, including 

elder financial exploitation.42

State and local authorities in the four states we visited told us current 

safeguards are not always sufficient to prevent exploitation by those older 

adults depend on for assistance. Although states are generally 

responsible for laws and regulations regarding these issues, the OAA 

directs the federal government to disseminate information about best 

practices to prevent elder abuse, including elder financial exploitation. 

According to our analysis, there is a role for the federal government to 

provide more information and guidance to prevent these types of elder 

financial exploitation.

Experts and federal, state, and local officials told us that older adults need 

more information about what constitutes elder financial exploitation in 

order to know how to avoid it.43

Each of the seven federal agencies we reviewed independently produces 

and disseminates public information on elder financial exploitation that is 

tailored to its own mission. For example, SEC produces information to 

educate investors about fraud prevention, including an investment guide 

for older adults. FTC publishes information to protect consumers, and 

AoA disseminates information to help reduce elder abuse, including elder 

financial exploitation. (See table 2 for examples of the types of 

information provided by each of these agencies.) These seven agencies 

However, APS and law enforcement 

officials told us that it is difficult for them to reach many older adults with 

this message and that they have little funding to promote public 

awareness. For example, in one California county officials reported that 

due to budget cuts, they had lost many positions that involved educating 

the public about elder financial exploitation.

 

42 In addition to criminal background checks, APS agencies in several states maintain a 

registry of elder abuse offenders that can be used to flag in-home caregivers who might 

financially exploit older adults. 

43 See appendix X for examples of activities undertaken by APS, criminal justice, and 

consumer protection agencies in California, Illinois, New York, and Pennsylvania to 

educate and inform older adults about elder financial exploitation. See appendix XI for 

examples of these activities undertaken by private organizations.

State and Federal Officials 

Called for Greater Focus 

on Public Awareness
 

Page 21 GAO-13-110 Elder Financial Exploitation

have also worked together at times to increase public awareness of elder 

financial exploitation. For example, each year FTC and the Postal 

Inspection Service collaborate on community presentations during 

National Consumer Protection Week.

Table 2: Selected Public Awareness Efforts of Federal Agencies Related to Elder Financial Exploitation

Agency Public Awareness Efforts

CFPB Office for Older Americans provides information for the public on its website about how to avoid being 

exploited. 

Published a guide for consumers about reverse mortgages. 

FTC Produces publications, pamphlets, and videos on a range of consumer protection issues, such as 

telemarketing fraud, and distributes them via its website, the media, and partnering organizations.

Piloted a partnership with the AARP Foundation that funds peer counseling for older adults or their relatives 

who think they have been victimized.

Works with AoA’s Senior Medicare Patrols to distribute educational materials to older adults and collect 

complaints.

AoA Distributes an e-newsletter discussing elder abuse, including financial exploitation.

Maintains Senior Legal Helplines.

Provides elder abuse prevention grants.

Collaborates with nonprofit Women’s Center for a Secure Retirement to provide a gateway for financial 

information for women.

Justice Provides grants to states, localities, and nonprofits for elder abuse prevention activities, including education 

and public awareness campaigns.

Provides information through its public websites on how individuals can protect themselves from and report 

various types of financial fraud.

SEC Distributes investor information that may relate to elder financial exploitation via its website, hotline, 

pamphlets, and regional events.

Provides an investment fraud guide for older adults.

Produces investor alert bulletins.

Works with AARP, FINRA, and state securities regulators on the Outsmarting Investment Fraud campaign. 

FinCEN Provides the public with information via its website on scams and resources for victims of fraud or identity 

theft.

Postal Inspection 

Service 

Deployed FakeChecks.org Campaign in 2007 to target international fraud schemes that are often directed 

toward older adults.

In 2010, sent a postcard containing information about preventing fraud, including elder financial exploitation, 

to every U.S. household.

Participated in AARP Town Hall meeting in 2011.

Conducts ongoing fraud prevention messaging on its website.

Makes community presentations on how to avoid scams during National Consumer Protection Week each 

March (with FTC).

Source: GAO analysis of agency documents and interviews.
 

Page 22 GAO-13-110 Elder Financial Exploitation

However, although the OAA calls for a coordinated federal elder justice 

system,44 which includes educating the public, the seven agencies we 

reviewed do not conduct these activities as part of a broader coordinated 

approach. In previous work, we found that agencies can use limited 

funding more efficiently by coordinating their activities and can strengthen 

their collaboration by establishing joint strategies.45 Similar calls for 

coordination were raised when the EJCC held its first meeting on October 

11, 2012, to begin implementing its mandate to coordinate federal elder 

justice activities and develop national priorities. As EJCC Chairman, the 

Secretary of HHS stated that combating elder abuse—which includes 

elder financial exploitation—is an “all-of-government” effort and that 

federal programs are not organized in a strategic way, which decreases 

their effectiveness. One expert noted that there is a clear need for a 

strategic, multi-faceted public awareness campaign on elder abuse. An 

official from the Financial Services Roundtable46 added that many 

agencies are trying to focus on awareness and education, but their efforts 

appear unorganized and uncoordinated.

 

44 42 U.S.C. § 3011(e)(2).

45 See GAO, Results-Oriented Government: Practices that Can Help Enhance and 

Sustain Collaboration Among Federal Agencies, GAO-06-15, (Washington, D.C.: October 

21, 2005).

46 The Financial Services Roundtable is an advocacy group with members from the 

banking, securities, investment, and insurance sectors. It aims to protect and promote the 

economic vitality and integrity of its members and the U.S. financial system.

Difficulty Gaining 

Expertise, Sustaining 

Collaboration, and 

Obtaining Data 

Hinders States’ 

Responses to Elder 

Financial Exploitation
 

Page 23 GAO-13-110 Elder Financial Exploitation

According to state and local officials we spoke with in four states, 

effectively investigating and prosecuting elder financial exploitation 

requires special skills and knowledge, which APS workers, law 

enforcement officers, and district attorneys sometimes lack. For example, 

APS officials noted that some case workers have little background or 

training in investigating financial crimes, and would find it difficult to 

respond to these cases. Local law enforcement officials also noted that 

they receive little training on elder financial exploitation and need 

additional training to build expertise. In addition, we were told that some 

prosecutors and judges are reluctant to take on cases of suspected elder 

financial exploitation because of competing priorities and limited 

resources, a continuing belief that elder financial exploitation is primarily a 

civil issue, or a view of older adult victims as unreliable witnesses.

State and local officials in the four states we reviewed are attempting to 

increase their expertise.47 For example, some state and local officials told 

us they attempt to acquire investigative expertise through formal and onthe-job training, by dedicating units or staff to investigate suspected cases 

of elder financial exploitation, or by contracting for assistance from 

certified fraud examiners or other forensic accountants.48

AoA and Justice have developed some resources that could be used to 

help state and local agencies build expertise in identifying, investigating, 

and prosecuting elder financial exploitation (see table 3).

However, state 

and local officials also told us that funding constraints limited their ability 

to build this additional expertise. Moreover, officials and experts told us 

that in order to more effectively allocate their limited resources, state and 

local entities would need more information about which practices have 

proven to be most effective for investigating, as well as preventing, elder 

financial exploitation.

 

47 See appendix X for examples of activities undertaken by APS, criminal justice, and 

consumer protection agencies in California, Illinois, New York, and Pennsylvania to build 

additional expertise. See appendix XI for examples of these activities undertaken by 

private organizations. 

48 Forensic accountants specialize in investigating financial crimes. The Certified Fraud 

Examiner credential is one professional designation that a forensic accountant may hold.

Special Knowledge and 

Skills Are Needed to 

Respond to Elder Financial 

Exploitation 
 

Page 24 GAO-13-110 Elder Financial Exploitation

Table 3: Examples of AoA and Justice Resources That Could Be Used to Increase State and Local Expertise about Elder 

Financial Exploitation

Agency Resource 

AoA National Center on Elder Abuse website has materials on elder abuse, including elder financial exploitation.

AoA makes formula grants to states and territories under Title VII of the Older Americans Act that are used to fund 

training.a

National Adult Protective Services Resource Center provides information and technical assistance aimed at APS 

professionals.

National Legal Resource Center provides training and information on legal issues affecting older adults.

Model Approaches to Statewide Legal Assistance Systems demonstration program includes two elder abuse projects 

that focus on elder financial exploitation.

Justice Funding the development of APS elder abuse training modules.

Justice’s Office on Violence Against Women, Office for Victims of Crime, and Bureau of Justice Assistance fund a 

number of trainings—including some material devoted to elder financial exploitation—to law enforcement and others in 

the field each year.

Prosecutors in the Criminal Division’s Fraud Section have provided training at national conferences on elder fraud.

Created an elder financial exploitation guide for police officers.

Plans to fund the development of online training for legal aid attorneys on identifying and responding to elder abuse, 

including financial exploitation.

Developing strategies and best practices for financial fraud and identity theft investigations.

Source: GAO analysis of HHS and Justice materials and interviews.

a 42 U.S.C. §§ 3058b and 3058i. 

Under the EJA, HHS is authorized to develop and disseminate best 

practices and provide training for APS workers,49 and AoA-supported 

resource centers compile information about elder abuse in general for 

easy access. However, information pertaining specifically to elder 

financial exploitation topics—such as mass marketing fraud, power of 

attorney abuse, or investment fraud—may be dated or more difficult to 

find because it is intermingled with other materials.50

Additionally, Justice officials told us that it would be beneficial for more 

training to be available to prosecutors of elder abuse. Justice has 

identified providing training and resources to combat elder abuse as a 

For example, AoA’s 

National Center on Elder Abuse (NCEA) has compiled a list of elder 

abuse training materials from a variety of sources, but we could find no 

quick and clear way to identify which trainings cover financial exploitation.

 

49 § 2042(a)(1)(C), 124 Stat. 794, 1397m-1(a)(1)(C). 

50 See appendix XIII for more information on AoA resource centers.
 

Page 25 GAO-13-110 Elder Financial Exploitation

strategy to achieve its objective of preventing and intervening in crimes 

against vulnerable populations. Justice officials indicated that they are 

developing an elder justice prosecution website that could serve as a 

resource and help build expertise. The website is expected to consolidate 

training materials in use across the country, primary litigation materials 

from local district attorneys, and information from relevant academic 

centers, such as the University of California at Irvine and Stanford 

University. However, it is unclear when this project will be completed, as 

Justice officials are waiting for materials from local district attorneys. As a 

result, prosecutors and other law enforcement officials currently do not 

have access to these materials.

The OAA requires AoA to develop a plan for promoting collaborative 

efforts to support elder justice programs at all levels.51 Officials we met 

from state and local social service and criminal justice agencies in three 

of the four states we reviewed said that while collaboration between their 

systems is important for combating elder financial exploitation, 

collaborating can sometimes be difficult because the two systems differ in 

the way they respond to exploitation and carry out their work. Specifically,

APS focuses on protecting and supporting the victim, and criminal justice 

focuses on prosecuting and convicting exploiters. However, according to 

experts, by working together, APS, the criminal justice system, and other 

partners can more easily accomplish both of these goals.52

 

51 42 U.S.C. § 3011(e)(2)(a)(ix). 

Experts have 

noted that some type of multidisciplinary response to elder abuse—

including elder financial exploitation—is prudent because of the complex 

52 See Adria E. Navarro et al., “Holding Abusers Accountable: An Elder Abuse Forensic 

Center Increases Criminal Prosecution of Financial Exploitation” (funded by Justice), The 

Gerontologist, vol. 0, (May 15, 2012). This study was funded by Justice.

States Identified 

Additional Federal Support 

Needed to Sustain Crucial 

Collaborations across 

Systems and Levels of 

Government

Collaboration between APS 

and Criminal Justice Systems
 

Page 26 GAO-13-110 Elder Financial Exploitation

nature of the problems faced by victims and the wide variety of responses 

required to help them and to prosecute exploiters.

In each of the four states we reviewed, local initiatives helped bridge the 

gap between APS and criminal justice agencies.53

Although multidisciplinary groups responding to elder financial 

exploitation already exist in each of the four states we visited and 

elsewhere, forming and sustaining these groups continues to be 

challenging, according to law enforcement officials in one state we visited 

and experts. Busy schedules and competing priorities make it difficult for 

some participants to attend meetings regularly, and a group’s focus 

influences how extensively members are willing to participate. For 

example, in one location officials told us that when the primary focus of 

their group shifted from prosecuting cases to providing services, 

participation by law enforcement officials declined. Collaborative efforts 

can also be undermined by a history of poor interaction between member 

organizations, differences in systemic understanding of elder financial 

exploitation, difficulties communicating across disciplines, different 

understandings of limits on information sharing, unclear roles, and failure 

to address the group’s long-term survival.

In some locations APS, 

criminal justice agencies, and other public and private entities have 

formed groups that meet periodically to develop awareness activities, 

foster information sharing, and discuss and resolve individual cases. 

Some multidisciplinary groups discuss elder abuse broadly, such as elder 

abuse task forces in some Pennsylvania counties and multidisciplinary 

groups in New York City. Others concentrate on financial exploitation 

specifically, such as the Philadelphia Financial Exploitation Task Force, 

and Financial Abuse Specialist Teams in some California counties.

54

 

53 See appendix X for examples of activities undertaken by APS, criminal justice, and 

consumer protection agencies in California, Illinois, New York, and Pennsylvania to 

support collaboration. See appendix XI for examples of these activities undertaken by 

private organizations.

However, information on 

relevant promising practices in this area could help promote creation of 

such groups—particularly when resources are limited—and ensure their 

success. 

54 Brandl et al., Elder Abuse Detection and Intervention (New York: 2007).
 

Page 27 GAO-13-110 Elder Financial Exploitation

Federal agencies have made some efforts to promote and inform 

collaboration between the APS and criminal justice systems in states. 

However, agencies have taken few steps to compile or disseminate 

promising practices in creating or sustaining multidisciplinary groups 

responding to elder financial exploitation, even though the OAA requires 

AoA to develop and disseminate information on best practices for adult 

protective services. AoA and Justice have offered a small number of 

grants to states to combat elder abuse or other crimes that require or 

encourage collaborative efforts such as multidisciplinary teams (see 

Table 4).

Table 4: Examples of Federal Grants That Encourage Collaboration among State Agencies That Respond to Elder Abuse

Agency Grant

AoA Elder Abuse Prevention Interventions Program: Requires grantees to have a partnership that includes 

at least the APS and criminal justice systems. AoA expected to award between $625,000 and $1.02 

million each to 5-8 grantees in 2012.

Elder Justice Community Collaborations: Relatively small ($10,000) grants specifically for setting up 

elder justice coalitions were awarded to over 40 grantees from 2007 to 2010.

Prevention of Elder Abuse, Neglect, and Exploitation (OAA Title VII-A3), formula grants to all states 

and territories that broadly require collaboration between social services and criminal justice systems.

Attorneys funded by Title IIIB of the Older Americans Act may work with APS in various situations, 

including situations dealing with guardianship issues.

Funding from AoA’s Model Approaches to Statewide Legal Assistance Systems demonstration grants 

may be used to support projects that address financial fraud in a collaborative fashion.

Justice (Office on Violence 

Against Women)

Enhanced Training and Services to End Violence Against and Abuse of Women Later in Life Program: 

Requires a partnership of criminal justice agencies, prosecutors, and nonprofits.

Source: GAO analysis of HHS and Justice documents and interviews.

AoA’s Elder Justice Community Collaborations program offered over 40 

$10,000 grants, along with technical assistance and training, from 2007 to 

2010 for the purpose of setting up elder justice coalitions. These 

coalitions, which included members across a broad range of disciplines, 

were required to create an elder justice strategic plan for their community, 

including plans for continuation beyond the grant period. This program 

was the only one we identified that was created specifically for the 

purpose of setting up new coalitions; other grants either allowed funds to 

be used for that purpose or required a coalition to be in place to 

implement the grant-funded initiative.

Interstate or international mass marketing scams include “grandparent 

scams,” which persuade victims to wire money to bail “grandchildren” out 

of jail or pay their expenses, and foreign lottery scams that require victims 

Collaboration on International 

and Interstate Financial Crimes
 

Page 28 GAO-13-110 Elder Financial Exploitation

to pay sizeable sums before they can receive their winnings.55 In 2011, 

the FBI’s Internet Crime Complaint Center56 received over 300,000 

complaints from victims of all ages about online fraud alone, with reported 

losses of about $485 million.

Local law enforcement authorities in the four states we visited indicated 

that investigating and prosecuting the growing number of cases involving 

interstate and international mass marketing fraud, which often target older 

adults, is particularly difficult for them. For example, coordinating with law 

enforcement authorities in other jurisdictions is labor intensive,57

 

55 Mass-marketing fraud refers generally to any type of fraud scheme that uses one or 

more mass communication techniques and technologies—such as the Internet, 

telephones, the mail, and even mass meetings in person—to contact, solicit, and obtain 

funds or other items of value from multiple victims in one or more jurisdictions. See 

appendix XIV for an example of a letter promoting a sweepstakes scam.

so state 

56 The Internet Crime Complaint Center is an online system that collects complaints of 

suspected criminal or civil Internet-related violations and develops referrals to law 

enforcement and regulatory agencies at the federal, state, local, tribal, and international 

levels. It is a partnership between the FBI and the National White Collar Crime Center, a 

nonprofit that supports the investigation and prosecution of economic and high-tech crime. 

57 According to the Fraud Section of Justice’s Criminal Division, lottery scam perpetrators 

are operating from a growing number of countries, including Costa Rica, the Dominican 

Republic, Jamaica, the Netherlands, Nigeria, and Spain.

International Mass Marketing Scam

From 2005 to 2009, about 100 older adults wired or mailed millions of dollars to scam 

artists working out of “boiler rooms” in a Middle Eastern country, in response to a 

phone call from “an attorney” claiming they had won a lottery or sweepstakes but had 

to first pay several thousand dollars in “taxes” or “fees” to receive their winnings. The 

perpetrators used information individuals had provided on sweepstakes entry forms to 

target older adults with some savings or assets, in particular. Many of the victims, who 

ranged in age from 70 to 80, suffered from debilitating conditions including Alzheimer’s 

or some other form of dementia. Once the perpetrators received a payment, they recontacted victims to inform them that they needed to send more. Victims typically did 

as they were told, continuing to send tens and even hundreds of thousands of dollars. 

To lend legitimacy to this elaborate scheme, victims were sent fake documents that 

appeared to come from the U.S. Internal Revenue Service or another government 

agency, and received calls from perpetrators impersonating public officials. In addition 

to losing their life savings, victims of this scam suffered emotional distress and 

declining health. The FBI was the lead U.S. investigating agency in this case. Six 

suspects pled guilty to conspiracy charges filed by the U.S. Attorney’s Office involving 

wire and mail fraud through telemarketing. Several were sentenced to between 40 and 

150 months in prison. Four more have been extradited to the United States and are 
 

Page 29 GAO-13-110 Elder Financial Exploitation

and local officials are often unable to pursue these cases themselves. 

Furthermore, even though various federal agencies have the authority to 

investigate and prosecute interstate and international scams (see fig. 3),58

 

58 In addition to the work of individual agencies, the Financial Fraud Enforcement Task 

Force—a broad coalition of more than 20 federal agencies, 94 U.S. Attorneys’ Offices, 

and state and local partners—was created by executive order to (1) investigate and 

prosecute significant financial crimes and other violations related to the current financial 

crisis and economic recovery efforts, (2) recover the proceeds of such crimes and 

violations, and (3) ensure just and effective punishment of those who perpetrate such 

crimes and violations. Exec. Order No. 13,519, 74 Fed. Reg. 60,123 (Nov. 19, 2009). The 

Consumer Protection Working Group formed under the Task Force in early 2012 focuses 

on strengthening the government’s collective efforts to address consumer-related scams 

targeting vulnerable populations.

local law enforcement officials told us there is not enough information 

available on whom they should contact when they need to refer a case to 

the federal level. They indicated that the lines of communication between 

local and federal agencies tend to be informal, based on whom local law 

enforcement officers know in a federal agency. Providing accurate 

contact information is consistent with Justice’s strategic objective for fiscal 

years 2012-2016 to strengthen its relationships with state and local law 

enforcement. Justice officials told us they believe that local officials know 

which federal officials to contact about international and interstate cases, 

but state and local law enforcement officials told us that it would be 

helpful to have more specific information. Cases that local officials do not 

refer to a federal agency due to a lack of correct contact information may 

not be investigated or prosecuted by either federal or local authorities.
 

Page 30 GAO-13-110 Elder Financial Exploitation

Figure 3: Federal Agencies’ Responsibilities in Combating International and Interstate Financial Crimes

a U.S. Attorneys also participate in the investigation of cases, either alone or in cooperation with other 

agencies.

In addition to not knowing whom to contact, state and local law 

enforcement officials in the four states we reviewed told us that they are 

concerned that federal agencies do not take enough of the cases that are 

referred to them. For example, a law enforcement official from California 

described a case of widespread interstate check fraud, expressing 

frustration with federal agencies that would not provide any support when 

he requested it. Federal officials, on the other hand, told us that they 

cannot take all cases referred to them by state and local law enforcement 

and that they must prioritize their caseload to make the best use of their 

limited resources. Justice and FTC officials said they tend to focus on 

larger cases in which many victims were affected or a significant amount 
 

Page 31 GAO-13-110 Elder Financial Exploitation

of money was lost, and Justice’s U.S. Attorneys also apply regional 

priorities, such as the vulnerability (including age) of the victim, when 

determining which cases to take.

Even if federal agencies choose not to take a case a state or local agency 

refers to them, officials told us that consistent referrals of cases by state 

and local authorities allow them to identify patterns or combine several 

complaints against the same individual into one case. FTC’s Consumer 

Sentinel Network database (Consumer Sentinel) collects consumer 

complaint data and aims to be an information-sharing tool to enable state 

and local law enforcement to become more effective.

59

FTC officials explained that while they have made attempts to get statelevel offices to contribute to the Consumer Sentinel, barriers such as 

reservations about data sharing, obsolete technological infrastructure, 

and severe budgetary cutbacks have kept the numbers of contributors 

low. When state officials do not contribute to the Consumer Sentinel, the 

information in the database does not give a national picture of the extent 

of cross-border scams. As a result of this—in addition to the impact of 

some law enforcement officials not using the system—it may be more 

difficult to combat these scams, and officials at all levels may not have the 

information they need to target their resources appropriately.

Justice officials 

said they encourage individuals and state and local authorities to file a 

complaint of suspected fraud to either the Consumer Sentinel or the FBI’s 

Internet Crime Complaint Center. However, while some state Attorneys 

General were familiar with the FTC database, local law enforcement 

officials we spoke with did not say that they reported cases to it or used 

its data. One official said he did not find the Consumer Sentinel database 

useful because law enforcement officials are not familiar with it.

According to state and local officials, banks are important partners in 

combating elder financial exploitation because they are well-positioned to 

recognize, report, and provide evidence in these cases. Indeed, frontline 

bank staff are able to observe elder financial exploitation firsthand. For 

 

59 FTC’s Consumer Sentinel Network is an online database that houses millions of 

consumer complaints available to law enforcement. Sentinel’s roster of 28 current data 

contributors includes 12 state attorneys general, the FBI’s Internet Crime Complaint 

Center, and the Council of Better Business Bureaus. More than 2,600 users from over 

2,000 law enforcement agencies worldwide use the system to share information, 

prosecute cases, conduct investigations, and pursue leads.

Working Cooperatively with 

Banks
 

Page 32 GAO-13-110 Elder Financial Exploitation

example, a bank teller who sees an older adult regularly is likely to notice 

if that individual is accompanied by someone new and seems pressured 

to withdraw money or if the older adult suddenly begins to wire large 

sums of money internationally.

There are state efforts and bank policies to help bank employees 

recognize exploitation. In Illinois, all state-chartered banks are required to 

train their employees on what constitutes elder financial exploitation.60

Banks may also help report suspected elder financial exploitation to local 

authorities. Training initiatives, such as Illinois’ program, encourage bank 

employees to report exploitation. Most of the six banks we spoke with had 

procedures in place for frontline employees to report suspected elder 

financial exploitation to bank management. Some of these banks also had 

internal units that are dedicated to receiving staff reports of elder financial 

exploitation and referring them to the proper authorities.

State and local agencies in California and Pennsylvania provide 

information and training to banks to help them recognize elder financial 

exploitation. Most of the six banks we spoke with had a policy for 

periodically training employees on identifying elder financial exploitation. 

In addition, these banks had a system in place that routinely monitors 

bank transactions for unusual activity and can help identify exploitation.

Notwithstanding such efforts, APS and criminal justice officials told us 

elder financial exploitation is generally underreported by banks.61

 

60 The Illinois Department on Aging designed and administered the training protocol and 

the Illinois Department of Financial and Professional Regulation certifies compliance with 

the training requirement.

Despite 

the training they receive, bank staff may not be aware of the signs of 

elder financial exploitation or know how to report it. In addition, in five of 

the six prosecuted cases we reviewed in depth, there were missed 

opportunities for banks to raise questions about transactions. For 

example, in one case, bank officials did not take any action in response to 

repeated withdrawals of large amounts of money that were not typical for 

61 Most states require some classes of professionals or organizations to report suspected 

elder abuse, which may include financial exploitation of older individuals, to state 

authorities. Some states, including California—a state we contacted—specifically include 

banks as mandatory reporters. Cal. Welf. & Inst. Code § 15630.1 (2012). Some states 

immunize individuals who make such reports in good faith from civil and/or criminal liability 

under state law. 
 

Page 33 GAO-13-110 Elder Financial Exploitation

that customer. Bank officials said they do report suspected elder financial 

exploitation, but also emphasized that banks are not law enforcement 

agencies. Officials said their primary responsibility is to protect customer 

assets and privacy and ensure customers have access to their funds. In 

addition, a banking association representative told us that even though 

federal privacy laws do not prohibit banks from reporting suspected 

abuse, banks are concerned that they will be held liable if they report 

suspected exploitation that is not later substantiated.

Three federal agencies—CFPB, AoA, and FinCEN—are positioned to 

encourage banks to identify and report elder financial exploitation, either 

due to the agency’s mission or via proposed or existing activities. The 

CFPB is the primary federal consumer protection regulator with respect to 

a variety of financial institutions, including banks. The Dodd-Frank Act 

authorizes the CFPB to protect consumers, including older adults, from 

abusive practices committed in connection with the offering or provision of 

consumer financial products or services.

62 In a November 2011 

congressional testimony, the Assistant Director of CFPB’s Office for Older 

Americans said the agency has a unique opportunity to help enhance, 

coordinate, and promote efforts of a variety of groups, including financial 

services providers.63

While the federal government generally requires banks to train employees 

on a variety of issues, such as money laundering, physical bank security, 

and information security,64

Banks are also required to file Suspicious Activity Reports (SAR) with 

FinCEN to alert them of potentially illegal bank transactions that involve, 

individually or in the aggregate, at least $5,000, which could include elder 

we could find no similar requirements for 

banks to train employees to recognize and report elder financial 

exploitation. However, AoA is considering collaborating with one large 

national bank on a project to encourage bank training on elder financial 

exploitation.

 

62 § 1031, 124 Stat. 1979-80 (12 U.S.C. § 5531). 

63 Testimony before the Subcommittee on Financial Institutions and Consumer Protection 

United States Senate Committee on Banking, Housing, and Urban Affairs (Washington, 

D.C., November 15, 2011).

64 31 U.S.C. § 5318(h)(1)(C), 12 C.F.R. § 21.3(a)(3), and pt. 30, app. B (2012). 
 

Page 34 GAO-13-110 Elder Financial Exploitation

financial exploitation.65 In February 2011, FinCEN issued an advisory to 

banks that described elder financial exploitation, provided potential 

indicators of elder financial exploitation, and requested the use of a 

specific term (“elder financial exploitation”) when applicable in SAR 

narratives related to this activity.66

Bank records can help investigators track an older adult’s use of funds 

over time and detect irregularities. APS officials in Pennsylvania told us 

that although Pennsylvania state law grants APS access to bank records, 

they are often denied access on the basis of federal privacy laws or the 

bank’s policies. APS officials from California, Illinois, and New York also 

reported that they are denied access to bank records for the same 

reasons.67 As a result, investigators are unable to obtain the information 

necessary to investigate suspected exploitation, identify perpetrators, 

stop further exploitation from occurring, or obtain restitution for victims. 

Bank officials told us the federal government could help clarify bank roles 

and responsibilities related to privacy and financial exploitation of older 

adults.68

There are two federal laws that generally protect the privacy of consumer

banking records: the Right to Financial Privacy Act of 1978 (RFPA)69

 

65 31 C.F.R. § 1020.320(a) (2012). If a financial institution knows, suspects, or has reason 

to suspect, for example, that transactions have no business or apparent lawful purpose or 

are not the sort in which a particular customer would normally be expected to engage, and 

the financial institution knows of no reasonable explanation for the transaction after 

examining the available facts, including the background and possible purpose of the 

transaction, the financial institution must file a SAR.

and 

66 FinCEN stores SARs in a database and each state has a law enforcement point-ofcontact with access to the database. Local police and district attorneys rely on their state’s 

FinCEN point-of-contact to obtain SAR information. While SARs could contain leads on 

elder financial exploitation cases, local officials we spoke with said they did not use SARs 

often to build criminal cases and SARs are not a vehicle for fast action. 

67 Local criminal justice agencies said that they are able to obtain bank records with a 

subpoena or search warrant, but banks sometimes take a long time to provide the 

records. This, in turn, extends already time-intensive investigations. 

68 The American Bar Association completed a report on this issue and concluded that 

federal privacy laws do not prohibit banks from sharing information in suspected cases of 

elder financial exploitation. American Bar Association, Can Bank Tellers Tell? Legal 

Issues Relating to Banks Reporting Financial Abuse of the Elderly (2003).

69 Pub. L. No. 95-630, tit. XI, 92 Stat. 3641, 3697-3710 (codified as amended at 12 U.S.C. 

§§ 3401-3422). 
 

Page 35 GAO-13-110 Elder Financial Exploitation

the Gramm-Leach-Bliley Act.70

The Gramm-Leach-Bliley Act generally prohibits financial institutions, 

including banks, from disclosing nonpublic personal information to third 

parties including, but not limited to, federal governmental authorities. 

Nonetheless, the act has a number of general exceptions permitting 

disclosure, such as: to protect against or prevent actual or potential fraud, 

unauthorized transactions, claims, or other liability; consistent with the 

RFPA, for an investigation on a matter related to public safety; or to 

comply with a properly authorized civil, criminal, or regulatory 

investigation, subpoena, or summons by federal, state, or local 

authorities.

Each establishes standards that banks 

must meet to safeguard customer banking information. The RFPA 

generally prohibits financial institutions, including banks, from providing 

any federal governmental authority with access to copies of information in 

any customer’s records without first providing notice to the customer. 

Because a government authority is defined in RFPA to include only 

federal agencies and officials, however, it should not prevent banks from 

reporting possible financial exploitation of older adults—or providing bank 

records to—state APS.

The NCEA and experts have called for more data on the cost of elder 

financial exploitation to public programs and for trend data on its extent. 

According to our analysis, these data could help determine what 

government resources to allocate and how best to prevent and respond to 

this problem. According to one Utah official, quantifying the impact of 

elder financial exploitation in that state helped that state’s legislators 

understand the importance of combating this problem and convinced 

them to simply decrease, rather than eliminate, state APS funding 

altogether.71

Similarly, data on the extent of elder financial exploitation over time could 

help state and local APS, as well as law enforcement agencies, assess 

However, according to our analysis, no other state has 

undertaken such a study.

 

70 Pub. L. No. 106-102, §§ 501-510, 113 Stat. 1338, 1436-1445 (codified as amended at 

15 U.S.C. §§ 6801-6809).

71 See Gunther, “The 2010 Utah Cost of Financial Exploitation.” 

Incomplete Data Hinder 

Efforts to Combat Elder 

Financial Exploitation
 

Page 36 GAO-13-110 Elder Financial Exploitation

the effectiveness of their efforts to combat it. The OAA72 and EJA both 

require the federal government to take steps to collect and disseminate 

data on all types of elder abuse,73 yet the studies federal agencies have 

funded in this area have produced little data on its extent over time, as we 

previously reported,74

Several federal agencies do collect administrative data on the number of 

complaints submitted by consumers or criminal cases that sometimes 

involve elder financial exploitation (see table 5)—data that could help 

state and local APS and law enforcement authorities determine what 

resources to allocate and how best to prevent and respond to this 

problem. Each agency publishes material containing a range of 

administrative data from its system that is available to the public. FTC, for 

example, publishes statistics from the Consumer Sentinel on the number 

and types of complaints, amount of losses, and characteristics of 

victims.

or on its cost.

75

Table 5: Federal Administrative Data Systems That Collect Incidents of Elder Financial Exploitation

Data System/Agency Information Collected Identifies Age of Victim? Contributors

FTC’s Consumer 

Sentinel Network 

Information on consumer complaints, 

including investment and mass marketing 

fraud, and identity theft. The FTC adds cases 

from the FBI’s Internet Crime Complaint 

Center to the Consumer Sentinel.

Optional. Less than half of 

complaints currently include 

age.

Some state and local law 

enforcement agencies, federal 

agencies, nongovernmental 

and private entities, and 

individuals.

FinCEN’s SAR Data Information on suspicious financial 

transactions, both actual and attempted. 

Option to identify suspected 

elder financial exploitationa

and age of victim. 

Banks and other financial 

institutions.

FBI’s Internet Crime 

Complaint Center 

Complaints about cyber-crime, including 

online fraud.

Age is a required field. State and local law 

enforcement agencies, as well 

as individuals.

Justice’s National 

Incident-Based 

Reporting System 

Each single incident of and arrest for 46 

crimes collected from state, local, and federal 

law enforcement agencies that participate in 

the system.

Age is a required field for 

individual victims.

State and local law 

enforcement agencies.

 

72 42 U.S.C. § 3012(e)(2)(A)(iii) and (iv), and (16). 

73 § 2042(a)(1)(B), 124 Stat. 794 (codified at 42 U.S.C. 1397m-1(a)(1)(B)). 

74 See GAO-11-208. 

75 FTC (2012) Consumer Sentinel Network Data Book for January - December 2011. 
 

Page 37 GAO-13-110 Elder Financial Exploitation

Data System/Agency Information Collected Identifies Age of Victim? Contributors

SEC’s Tips, 

Complaints, and 

Referrals Portal

Complaints about investments or financial 

professionals.

Information about age is 

not required.

All sources, including individual 

investors.

Source: GAO analysis of documents provided and interviews granted by FTC, FinCEN, Justice, and SEC.

a In 2012, FinCEN released a revised SAR that includes a check box that enables filers to indicate 

clearly that they are reporting suspected elder financial exploitation. The revised SAR is currently 

available for use, and will become mandatory at the end of March 2013, according to FinCEN 

officials.

While the number of reported incidents of elder financial exploitation in 

each agency’s system represents only a portion of all cases that actually 

occur in a given period and geographic area, the number over time could 

provide an indication of fluctuations in the extent of certain types of elder 

financial exploitation.

Data from the Consumer Sentinel could be of particular interest to state 

and local APS and law enforcement authorities, because over half of the 

consumer complaints reported to this system involve financial exploitation 

through fraud. Individual complaints can be directly reported to the 

Consumer Sentinel by victims or others on their behalf. Cases reported to 

the FBI Internet Crime Complaint Center and non-governmental 

organizations, such as the Council of Better Business Bureaus, are also 

added to the complaints in the Consumer Sentinel. Currently, however, 

the Consumer Sentinel does not receive any of the complaints reported to 

any of the law enforcement or consumer protection agencies in 38 states. 

Moreover, less than half the complaints in the Consumer Sentinel contain 

the age of the victim because FTC does not require complaints to include 

this information or other indicators of whether the case involved elder 

financial exploitation.

76

In 2011, we found that state-level APS data could provide useful 

information on the extent of elder abuse, including elder financial 

exploitation, over time. We recommended that AoA work with states to 

FTC officials told us the agency does not require 

complaints to include the age of the victim because of concerns regarding 

privacy and the potential burden this might place on individual 

complainants. In contrast, SARs in the FinCEN system will soon all be 

clearly identified when a filing institution reports suspected elder financial 

exploitation.

 

76 See appendix XV for additional information on the data in the Consumer Sentinel 

Network.
 

Page 38 GAO-13-110 Elder Financial Exploitation

develop a nationwide system to collect and compile these data.77 AoA 

officials told us they have initiated discussions with states about 

establishing such a system, but have been unable to develop a 

comprehensive plan for implementing one due to a lack of funding.

Elder financial exploitation is a multi-faceted problem spanning social 

service, criminal justice and consumer protection systems of government. 

As a result, combating it is challenging and requires action on the part of 

not only many state and local agencies, but also multiple agencies at the 

federal level. Each of the seven federal agencies we reviewed is working 

to solve this problem in ways that are consistent with its own mission. 

However, the problem is large and growing. It calls for a more cohesive 

and deliberate approach governmentwide that, at a minimum, identifies 

gaps in efforts nationwide, ensures that federal resources are effectively 

allocated, establishes federal agency responsibilities, and holds agencies 

accountable for meeting them.

The EJCC has recognized that combating elder abuse, including elder 

financial exploitation, is an effort that requires federal agencies to work 

together. A clearly articulated national strategy is needed to coordinate 

and optimize such federal efforts to effectively prevent and respond to 

elder financial exploitation, and the EJCC can be the vehicle for defining 

and implementing this strategy. In the current economic climate, state and 

local APS and law enforcement agencies will find it increasingly difficult to 

cope with growing numbers of cases without a national strategy attuned 

to their need for information and guidance on preventing and responding 

to elder financial exploitation, as well as additional data on its extent and 

impact.

In addition to working together to build a national strategy to combat elder 

financial exploitation, there are a number of ways individual federal 

agencies could better support state and local APS and law enforcement 

agencies. For example, Justice has identified providing training and 

resources to combat elder abuse as a strategy to achieve its objectives of 

preventing and intervening in crimes against vulnerable populations. 

Without easily accessible information and guidance tailored to the needs 

of prosecutors nationwide, they may continue, given limited resources, to 

 

77 See GAO-11-208. 

Conclusions 
 

Page 39 GAO-13-110 Elder Financial Exploitation

make such cases a low priority. Similarly, many cases cross jurisdictions 

and could involve multiple victims or have perpetrators located in other 

countries. These cases may not be investigated or prosecuted unless 

state and local law enforcement have better information on the process 

for contacting the federal government regarding these cases or the ways 

in which the federal government could provide support.

Without information to correct banks’ misconceptions about the impact of 

federal privacy laws on their ability to release bank records, APS and law 

enforcement agencies will continue to find it difficult to obtain the 

information they need from banks to investigate suspected cases of elder 

financial exploitation. Moreover, without educating bank employees 

nationwide on how to identify and report suspected elder financial 

exploitation, many cases will continue to go unreported, uninvestigated, 

and unprosecuted. The CPFB is positioned to provide additional 

information to banks, as part of the agency’s consumer protection 

regulatory function and dedication to protecting the financial health of 

older Americans.

Finally, to fulfill its mission of protecting consumers against unfair, 

deceptive, or fraudulent practices, the FTC established the Consumer 

Sentinel Network database to enhance information-sharing and support 

law enforcement at all levels. The Consumer Sentinel could serve as a 

valuable source of data on the extent of some types of elder financial 

exploitation nationwide and as an important resource for law enforcement 

authorities as they identify, investigate, and prosecute cases. The 

Consumer Sentinel’s usefulness in this area, however, will continue to be 

limited until the number of contributors to it is increased and complaints 

are required to include the age of the victim or other indicators of whether 

the case involved elder financial exploitation. In the absence of the latter, 

it is difficult to determine the number of financial exploitation complaints 

that involve older adults, which in turn makes any Consumer Sentinel 

data contributed less useful to state and local APS and law enforcement 

agencies.

To coordinate and optimize federal efforts to prevent and respond to elder 

financial exploitation, we recommend the Secretary of HHS, as chairman 

of the Elder Justice Coordinating Council, direct the Council to develop a 

written national strategy for combating this problem. This strategy should 

include a clear statement of its purpose and goals and indicate the roles 

and responsibilities particular federal agencies should have in 

Recommendations for 

Executive Action
 

Page 40 GAO-13-110 Elder Financial Exploitation

implementing it. The strategy could address, among other things, the 

need to

• identify and disseminate promising practices and other information 

nationwide that can be used by state and local agencies to 

prevent exploitation, educate the public, and help state and local 

agencies collaborate, investigate, and prosecute elder financial 

exploitation;

• ensure coordination of public awareness activities across federal 

agencies; and

• collect and disseminate better data nationwide to inform federal, 

state, and local decisions regarding prevention of and response to 

elder financial exploitation.

To develop expertise among prosecutors and other criminal justice 

officials, we recommend the Attorney General establish timeframes for 

and take the steps necessary to launch the elder justice prosecution 

website that Justice has begun to construct.

To facilitate investigation and prosecution of interstate and international 

elder financial exploitation, we recommend the Attorney General conduct 

outreach to state and local law enforcement agencies to clarify the 

process for contacting the federal government regarding these cases and 

the ways in which the federal government could provide support.

To encourage banks to identify and report suspected elder financial 

exploitation and to facilitate release of bank records to APS and law 

enforcement authorities for investigating this activity, we recommend the 

Director of the Consumer Financial Protection Bureau

• develop a plan to educate banks nationwide on how to identify 

and report possible elder financial exploitation; and

• develop and disseminate information for banks on the 

circumstances under which they are permitted, under federal 

privacy laws, to release relevant bank records to law enforcement 

and APS agencies.

To increase the usefulness of data from the Consumer Sentinel Network 

database for federal, state, and local investigation and prosecution of 

elder financial exploitation, we recommend the Chairman of the Federal 

Trade Commission:
 

Page 41 GAO-13-110 Elder Financial Exploitation

• take additional steps to encourage more state and local law 

enforcement authorities nationwide to report to the Consumer 

Sentinel relevant individual complaints they receive of elder 

financial exploitation and to encourage and enable these 

authorities to query the system; and

• study the feasibility of requiring that all complaints to the 

Consumer Sentinel include either the victim’s age or an indication 

of whether the complaint involves elder financial exploitation

We provided a draft of this report to the seven federal agencies that we 

reviewed for their comments. CFPB concurred with our recommendations 

and agreed that a collaborative and coordinated effort by federal agencies 

can help optimize strategies to combat elder financial exploitation (see 

appendix XVI). CFPB further noted that financial institutions can play a 

key role in preventing and detecting elder financial exploitation, and that 

CFPB is collecting information on financial institution training programs 

and considering how best to help institutions that request this information. 

HHS indicated in its general comments that our recommendations are 

consistent with what it heard during the inaugural meeting of the EJCC, 

and added that it looks forward to working with Congress to continue 

implementing the EJA (see appendix XVII). 

In an e-mailed response, FTC’s Bureau of Consumer Protection noted 

that the Consumer Sentinel database provides law enforcement with 

access to millions of consumer complaints. FTC added that the database 

has no required fields, and expressed its belief that if consumers were 

required to provide detailed personal information as a condition to filing a 

complaint, they might refuse to do so, thereby decreasing the overall 

effectiveness of the system. FTC explained that almost 48 percent of all 

fraud complaints in 2011 included the voluntary submission of age, and 

that nearly half of its non-individual data contributors do not submit age 

information in the data they provide to FTC. Given the potential for the 

Consumer Sentinel database to support and enhance state and local law 

enforcement agencies’ response to elder financial exploitation, 

particularly interstate and international cases, we continue to believe that 

FTC should study the feasibility of requiring that all complaints to the 

Consumer Sentinel database include the victim’s age or another indicator

of whether the complaint involves elder financial exploitation. In doing so, 

FTC can examine different options, including the use of a check box 

similar to the one that FinCEN has included in its SARs.

Response to Agency 

Comments
 

Page 42 GAO-13-110 Elder Financial Exploitation

We are sending copies of this report to the seven agencies we reviewed, 

relevant congressional committees, and other interested parties. We will 

also make copies available to others upon request. The report is available 

at no charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or brownke@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix XVIII. 

Kay E. Brown, Director

Education, Workforce, and Income Security Issues
 

Page 43 GAO-13-110 Elder Financial Exploitation

List of Requesters

The Honorable Herb Kohl

Chairman

Special Committee on Aging

United States Senate

The Honorable Bernard Sanders

Chairman

Subcommittee on Primary Health and Aging

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable Richard Blumenthal

United States Senate

The Honorable Jeff Merkley

United States Senate

The Honorable Bill Nelson

United States Senate

The Honorable Sheldon Whitehouse

United States Senate
Appendix I: Administration on Aging 

Relevant agency divisions

Assistant Secretary for Aging: Assists the Secretary with activities that 

address challenges and opportunities for older adults

Office of Elder Rights: Administers the provisions of the Older 

Americans Act related to elder abuse prevention

Selected activities

• Funds and oversees the National Center for Elder Abuse (NCEA; 

www.ncea.aoa.gov), a national resource center dedicated to 

preventing elder abuse

• Funded the National Adult Protective Services Resource Center, 

which provides information and technical assistance to APS officials

• Provides formula grants to State Units on Aging in each state to 

prevent elder abuse

• Provides funds to local legal services providers, which may use the 

funds to assist elder financial exploitation victims

• AoA’s Model Approaches to Statewide Legal Assistance Systems 

program funds demonstration grants, which aim to strengthen states’ 

legal services networks, may be used to support projects that address 

elder financial exploitation

Coordination with other agencies

• Works with state aging agencies to help them develop statewide plans 

to combat elder abuse

• Through NCEA, partnered with Treasury on its Go Direct financial 

literacy campaign

• Partnered with Treasury and the Financial Services Roundtable on a 

toolkit for training financial institutions on elder financial exploitation

• Worked with the SEC on several Seniors Summits that brought 

agencies together to discuss elder financial exploitation

• Chairs the Elder Justice Coordinating Council, a collaborative body of 

federal agencies created under the EJA to recommend federal policies 

to combat elder abuse and ways federal agencies should coordinate to 

implement these policies.

• Co-leads an informal interagency workgroup that helps facilitate 

federal elder justice activities.

1 On April 16, 2012, AoA became part of the Administration for Community Living, which also includes HHS’s Office 

on Disability and Administration on Developmental Disabilities.

Mission

To develop a comprehensive, 

coordinated, and cost-effective 

system of home- and communitybased services that helps elderly 

individuals maintain their health 

and independence.

How agency prioritizes

elder financial exploitation 

Strategic goal of ensuring the rights 

of older people and preventing their 

abuse, neglect, and exploitation.

Agency’s role in combating 

elder financial exploitation

The Older Americans Act 

Amendments of 1965 calls for AoA 

to develop objectives, priorities, 

policy, and a long-term plan for 

facilitating the development of a 

coordinated, multidisciplinary elder 

justice system in the United States

The Elder Justice Act of 2009

(EJA) calls for HHS to, among 

other things:

• collect and disseminate data 

related to exploitation, 

• conduct research on and 

develop information on best 

practices for Adult Protective 

Services (APS), 

• provide technical assistance to 

APS, and

• establish centers to conduct 

research, develop expertise, 

and improve law enforcement’s 

ability to combat elder financial 

exploitation

Contact information

Call: (202) 619-0724

Email: aoainfo@aoa.hhs.gov

Source: GAO analysis of AoA documents and interviews.

Administration on Aging (HHS)1

Page 44 GAO-13-110 Elder Financial Exploitation
Appendix II: Consumer Financial Protection Bureau

Organization

Selected activities

• Posts information for older adults on website 

• Conducts research on issues affecting older Americans, such as 

reverse mortgages, financial advisors and their credentials, and 

fiduciaries

• Gathering information from the public on elder financial exploitation to 

learn more about the ways in which older adults are financially 

exploited and best practices for elder financial management. CFPB

expects to share its results in 2013. 

Coordination with other agencies

• Member of the Elder Justice Coordinating Council

• Member of Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime 

• Works with AoA, Justice, Department of Labor, and SEC on various 

projects related to protecting older Americans

Mission

To implement and enforce federal 

consumer financial law consistently 

for the purpose of ensuring that all 

consumers have access to markets 

for consumer financial products 

and services and that markets for 

consumer financial products and 

services are fair, transparent, and 

competitive

How agency prioritizes

elder financial exploitation 

Agency’s organizing statute 

requires emphasis on older 

Americans and protecting them 

from financial exploitation

Agency’s role in combating 

elder financial exploitation

Leadership: Office for Older 

Americans is the first federal office 

dedicated to the financial health of 

older Americans

Information dissemination:

Provides information to consumers

and to others who assist them in 

combating elder financial 

exploitation

Supervision and Enforcement:

Supervises certain banks and 

nonbanks and brings enforcement 

actions when appropriate

Rulemaking: Issues rules, orders, 

and guidance

Contact information

Call: (855) 411-2372

General Information: 

www.consumerfinance.gov

Source: GAO analysis of CFPB documents and interviews.

Consumer Financial Protection Bureau 

(CFPB)

Page 45 GAO-13-110 Elder Financial Exploitation
Appendix III: Federal Trade Commission

Relevant agency divisions

Bureau of Consumer Protection: Works to protect consumers against 

unfair, deceptive, or fraudulent practices in the marketplace. The Bureau 

conducts investigations, sues companies and people who violate the law, 

develops rules to protect consumers, and educates consumers and 

businesses about their rights and responsibilities. The Bureau also 

collects complaints about consumer fraud and identity theft and makes 

them available to law enforcement agencies across the country.

• The Divisions of Advertising Practices, Enforcement, Financial 

Practices, Marketing Practices, and Privacy and Identity 

Protection, and FTC Regional Offices are involved to some extent in 

the Bureau’s elder financial exploitation activities.

• The Division of Consumer and Business Education’s mission is to 

give consumers the tools they need to make informed decisions and to 

give businesses the tools they need to comply with law. The Division 

produces, promotes, and disseminates information that is timely, 

targeted, objective, actionable, and in plain language. 

Selected activities

• The Enforcement Division, as part of its overall mission, has dedicated 

resources to investigating misrepresentations aimed at the “oldest old” 

and their caretakers. In 2012, the Division settled two administrative 

cases with companies that misrepresented the services they provide 

when referring seniors to long-term care facilities. 

• In April 2012, the Division of Privacy and Identity Protection gathered 

information on the types of senior identity theft, how it happens, and 

possible solutions. 

• FTC actively prosecutes fraudulent telemarketers, online and direct 

mail merchants engaged in a wide variety of deceptive scams. 

Coordination with other agencies

• Member of Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime 

• May work with international, federal, state, and local law enforcement 

officials to investigate cases and bring enforcement actions against 

scammers

• Hosts Common Ground Conferences that bring federal, state, local 

agencies and non-profit organizations together to share information on 

scams 

Mission

To prevent business practices that 

are anticompetitive, deceptive, or 

unfair to consumers; to enhance 

informed consumer choice and 

public understanding of the 

competitive process; and to 

accomplish this without unduly 

burdening legitimate business 

activity 

How agency prioritizes

elder financial exploitation 

FTC identifies older adults as a 

target population for its consumer 

education efforts. Elder financial 

exploitation is included as part of 

the Bureau of Consumer 

Protection’s responsibility to protect 

all consumers. 

Agency’s role in combating 

elder financial exploitation

Legal action: Investigates and 

prosecutes large-scale fraud cases

Information dissemination:

Provides educational materials to 

consumers

Data collection: FTC’s Consumer 

Sentinel database stores individual 

fraud complaints; other federal, 

state, and local agencies use and 

submit information to the database

Contact information

1-877-FTC-HELP (1-877-382-4357)

General information:

www.ftc.gov

To submit a complaint online: 

www.ftccomplaintassistant.gov/

Source: GAO analysis of FTC documents and interviews.

Federal Trade Commission (FTC)

Page 46 GAO-13-110 Elder Financial Exploitation
Appendix IV: Financial Crimes Enforcement Network

Organization

Selected activities

• Provides analytical support to law enforcement investigations and

access to Suspicious Activity Reports collected from financial 

institutions under the Bank Secrecy Act of 1970

• Regulates financial institutions, requiring them to have anti-money 

laundering programs and to report suspicious activity, including elder 

financial exploitation

• Issued advisory to financial institutions with information about how to 

identify and report elder financial exploitation

Coordination with other agencies

• Member of Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime

a Pub. L. No. 91-508, 84 Stat. 1114 (codified as amended at 12 U.S.C. §§ 1829(b), 1951-1959; 31 

U.S.C. §§ 5311-5330).

b The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and 

Obstruct Terrorism (USA PATRIOT ACT) Act of 2001, Pub. L. No. 107-56, 115 Stat 272 (2001). We 

refer to this act as the USA PATRIOT Act.

Mission 

To enhance the integrity of 

financial systems by facilitating the 

detection and deterrence of 

financial crime

How agency prioritizes

elder financial exploitation 

FinCEN does not specifically 

identify protecting older adults in its 

agency priorities; however, it 

recently released a new Suspicious 

Activity Report form that enables 

financial institutions specifically to 

identify suspected elder financial 

exploitation

Agency’s role in combating 

elder financial exploitation

Law enforcement: FinCEN 

supports financial criminal 

investigations, most often those 

involving money laundering

Data collection: FinCEN 

aggregates data reported by 

financial institutions on suspicious 

activity reports, including reports of 

suspected elder financial 

exploitation

Rulemaking: FinCEN can issue 

rules and regulations implementing 

the Bank Secrecy Act of 1970a

(anti-money laundering), as 

amended by the USA PATRIOT 

Actb 

Contact information

Regulatory Helpline :

(800) 949-2732

General information:

http://www.fincen.gov

Source: GAO analysis of FinCEN documents and interviews.

Financial Crimes Enforcement Network

(FinCEN) 

Page 47 GAO-13-110 Elder Financial Exploitation
Appendix V: Department of Justice

Organization

Selected activities

• Prosecutes perpetrators of elder financial exploitation

• Conducts public awareness activities on elder financial exploitation

• Office on Violence Against Women and Office for Victims of Crime 

both provide grants for training that includes elder financial exploitation

• Bureau of Justice Statistics and National Institute of Justice both fund 

or conduct studies on elder financial exploitation

• See FBI and U.S. Attorney pages for details on those agencies

Coordination with other agencies

• Mandated member of Elder Justice Coordinating Council

• Member of Elder Justice Working Group

• Coordinates the Financial Fraud Enforcement Task Force, which 

brings numerous federal agencies together to prevent, investigate, and 

prosecute financial crime

Mission

To enforce the law and defend the 

interests of the United States 

according to the law; to ensure 

public safety against threats foreign 

and domestic; to provide federal 

leadership in preventing and 

controlling crime; to seek just 

punishment for those guilty of 

unlawful behavior; and to ensure 

fair and impartial administration of 

justice for all Americans

How agency prioritizes

elder financial exploitation 

Priority goal of protecting 

vulnerable populations, including 

the elderly

Agency’s role in combating 

elder financial exploitation

Assistance to victims: Provided 

as part of the Victims of Crime Act 

Crime Victims Fund and Violence 

Against Women Act of 1994, as 

amended

Research, technical assistance, 

and training: Funds research in 

the field of elder abuse and 

technical assistance and training to 

those in the field

Law enforcement: Investigates 

fraud crimes and makes arrests

Legal action: Prosecutes fraud 

cases 

Contact information

Main number:

202-514-2000

On the web:

www.justice.gov

Source: GAO analysis of Justice documents and interviews.

Department of Justice

Page 48 GAO-13-110 Elder Financial Exploitation
Appendix VI: Federal Bureau of Investigation

Organization

56 field offices located in major metropolitan areas and in Puerto Rico, as 

well as legal attaches in U.S. embassies around the world

Selected activities

• Responds to complaints from victims of crime

• Investigates selected cases of potential elder financial exploitation. 

• Internet Crime Complaint Center receives complaints about internetrelated crime and shares them with the Federal Trade Commission 

(FTC) Consumer Sentinel Network database and federal, state, and 

local law enforcement offices as appropriate

• Conducts outreach about elder financial exploitation to local entities 

such as nursing homes and financial institutions

Coordination with other agencies

• Works with local U.S. Attorneys’ offices to make determinations about 

whether to open or continue investigations of potential elder financial 

exploitation cases

• Works with other federal and state agencies, such as the U.S. Postal 

Inspection Service, to conduct investigations

• May work jointly with foreign law enforcement agencies to investigate 

international mass marketing fraud cases

• Coordinates with the National White Collar Crime Center to run the 

Internet Crime Complaint Center (see above)

• Maintains Memorandum of Understanding with the FTC to get access 

to FTC’s Consumer Sentinel Network database 

• Participates in regional task forces on financial crime

• Member of Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime

Mission

To protect and defend the United 

States against terrorist and foreign 

intelligence threats, to uphold and 

enforce the criminal laws of the 

United States; and to provide 

leadership and criminal justice 

services to federal, state, 

municipal, and international 

agencies and partners

How agency prioritizes

elder financial exploitation 

Priority goal of combating 

financial/white collar crime. Mass 

marketing fraud, which may include 

elder financial exploitation, ranks 

fourth among the FBI’s financial 

crime priorities

Agency’s role in combating 

elder financial exploitation

Law enforcement: Investigates 

fraud crimes and makes arrests

Contact information

Main number:

202-324-3000

On the web:

www.fbi.gov

To find your field office:

www.fbi.gov/contact-us/field

Source: GAO analysis of FBI documents and interviews.

Department of Justice

Federal Bureau of Investigation (FBI) 

Page 49 GAO-13-110 Elder Financial Exploitation
Appendix VII: U.S. Attorneys

Organization

94 offices across the country and in U.S. territories 

Selected activities

• Prosecutes perpetrators of elder financial exploitation

• Provides assistance to elder financial exploitation victims

Coordination with other agencies

• May receive cases from other federal agencies, such as the FBI, the 

Postal Inspectors, and the SEC, as well as from state and local 

agencies 

• May pursue cases in conjunction with partner agencies

• Participates in regional task forces on financial crime

• Member of the Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime

Mission

As the nation’s principal litigators, 

U.S. Attorneys prosecute criminal 

cases brought by the federal 

government; prosecute and defend 

civil cases in which the United 

States is a party; and collect 

certain debts owed to the federal 

government

How agency prioritizes

elder financial exploitation 

Each U.S. Attorney exercises wide 

discretion in determining which 

cases to pursue to best use the 

office’s resources to further the 

priorities and needs of their 

jurisdiction. Offices may prioritize 

investment and securities fraud

Agency’s role in combating 

elder financial exploitation

Law enforcement: Investigates 

fraud crimes and makes arrests

Legal action: Prosecutes fraud 

cases 

Contact information

On the web:

www.justice.gov/usao

To find your field office:

http://www.justice.gov/usao/about/

offices.html

Source: GAO analysis of Justice documents and interviews.

Department of Justice 

U.S. Attorneys

Page 50 GAO-13-110 Elder Financial Exploitation
Appendix VIII: U.S. Postal Inspection Service

Organization

Selected activities

• 2010 mass mailing to every U.S. household on fraud, including elder 

financial exploitation 

• Community presentations about scams during National Consumer 

Protection Week

• Participates in community discussions about mail fraud, such as an 

AARP Town Hall meeting and a panel discussion hosted by Stanford 

Research Center on the Prevention of Financial Fraud

• Plans to have a campaign in 2013 on preventing fraudulent lottery 

schemes, focusing on older adults

Coordination with other agencies

• Member of the Elder Justice Coordinating Council

• Member of the Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime 

• Collaborates with Canadian and Jamaican criminal justice systems on 

international fraud

• Collaborates with FTC on National Consumer Protection Week

Mission

To support and protect the U.S. 

Postal Service and its employees, 

infrastructure, and customers; 

enforce the laws that defend the 

nation’s mail system from illegal or 

dangerous use; and ensure public 

trust in the mail

How agency prioritizes

elder financial exploitation 

The Postal Inspection Service does 

not specifically identify protecting 

older adults in its agency priorities; 

however, older adults are often 

victimized in the mail fraud 

schemes it investigates

Agency’s role in combating 

elder financial exploitation

Law enforcement: Investigates 

mail fraud crimes and makes 

arrests and has administrative 

authority to shut down addresses 

used for fraud

Information dissemination:

Provides information to the public 

about mail fraud

Data collection: Tracks data on its 

cases, mines data for trends, and 

shares this data with FTC’s 

Consumer Sentinel Network

database

Contact information

Main number:

1-877-876-2445

On the web:

postalinspectors.uspis.gov

Source: GAO analysis of agency documents and interviews.

United States Postal Inspection Service

Page 51 GAO-13-110 Elder Financial Exploitation
Appendix IX: Securities and Exchange Commission

Relevant agency divisions

Office of Investor Education and Advocacy: Carries out SEC’s investor 

education program; responds to questions and complaints from members 

of the public; and reviews agency rulemaking from the perspective of the 

individual investor 

Division of Enforcement: Conducts investigations into possible violations 

of the federal securities laws, and prosecutes cases in civil suits in the 

federal courts, and in administrative proceedings before an administrative 

law judge

Office of Compliance Inspections and Examinations: Administers the 

SEC’s nationwide examination and inspection program and conducts 

inspections to foster compliance with securities laws and to detect 

violations of the laws

Division of Trading and Markets: Assists the Commission in executing 

its responsibility for maintaining fair, orderly, and efficient markets, 

including day-to-day oversight of major securities market participants

Selected activities

• Published A Guide for Seniors: Protect Yourself Against Investment 

Fraud

• Produced reports on free lunch seminars and promising practices that 

businesses can undertake to prevent and detect fraud against older 

adults

• Maintains a website that allows investors are able to research 

investment advisor firms, and provides a link to a similar website for 

brokers on the Financial Industry Regulatory Authority’s (FINRA) 

website

• Issues approximately 25 investor alerts and bulletins per year

• Works with FINRA, AARP, and state securities regulators on the 

Outsmarting Investment Fraud campaign, which is designed to reduce 

investment fraud among older adults

Coordination with other agencies

• Member of Financial Fraud Enforcement Task Force, which brings 

numerous federal agencies together to prevent, investigate, and 

prosecute financial crime 

• Participates in the multi-agency Financial Literacy and Education 

Commission, which coordinates federal financial education efforts and 

developed a national strategy for financial literacy 

Mission

To protect investors; maintain fair, 

orderly, and efficient markets; and 

facilitate capital formation

How agency prioritizes

elder financial exploitation 

SEC does not specifically identify 

elder financial exploitation as a 

priority, but it does identify older 

adults as a target population for its 

investor education, enforcement, 

and industry-compliance related

efforts

Agency’s role in combating 

elder financial exploitation

Supervision of investment 

professionals: Conducts exams 

and inspections of investment 

professionals, such as brokerdealers, investment companies, 

and investment advisors 

Legal action: Conducts 

investigations and prosecutes 

violations of the federal securities 

laws

Information dissemination:

Provides educational materials to

investors 

Rulemaking: Establishes rules on 

matters affecting the operations of 

securities markets

Contact information

Investor Information Service:

1-800-SEC-0330

www.sec.gov

www.investor.gov

Source: GAO analysis of SEC documents and interviews.

Securities and Exchange Commission (SEC)

Page 52 GAO-13-110 Elder Financial Exploitation
Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation

Page 53 GAO-13-110 Elder Financial Exploitation

State 

Efforts to Prevent 

Exploitation by Financial 

Services Providers, 

Power-of-Attorney 

Agents, and Paid in-Home 

Caregivers

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions Responding 

to Exploitation

California Napa County

• Caregiver Ordinance – 

all in-home caregivers 

must submit to and

pass a background 

check and obtain a 

permit to provide 

services

State Law

• Mandatory elder abuse 

reporting for health 

care professionals, 

social workers, nursing 

home workers, and 

employees of banks 

and credit unions

• Discretionary 

background checks for 

paid in-home 

caregivers

Department of Corporations

• Seniors Against 

Investment Fraud—

older adults are able to 

check the licensing 

status of financial 

services professionals

San Bernardino County 

APS

• Scam blasts are sent 

to senior centers and 

law enforcement 

agencies to alert older 

adults of potential 

scams.

• “It’s not your fault” 

publication —campaign 

to reduce elder 

financial exploitation 

stigma among older 

adults

San Joaquin District 

Attorneys Offices

Communities Against 

Senior Exploitation—

representatives from the 

District Attorney’s office 

provide examples of 

financial fraud and tips for 

personal safety and 

protecting personal 

information

San Francisco District 

Attorney’s Office

• “Elder Financial Abuse 

the Invisible Crime” —

outreach/public 

awareness campaign 

with posters in different 

languages urging 

individuals to report 

suspected elder 

financial abuse to APS

Department of Corporations

• Seniors Against 

Investment Fraud—

alerts and educates 

Californians over the 

age of 50 about 

financial and 

investment fraud, 

Institute on Aging

• Houses the San 

Francisco Elder Abuse 

Forensic Center, which 

works to improve 

coordination among 

those responding to 

elder abuse cases; 

assists victims; and 

educates professionals 

and the general public 

on preventing, 

reporting, and stopping 

elder abuse

San Bernardino County 

APS

• Shift change briefings 

and pocket guide to 

elder abuse penal 

codes for local law 

enforcement

Center of Excellence on 

Elder Abuse and Neglect at 

UC Irvine

• Central source of 

technical assistance, 

multidisciplinary 

training, research, and 

policy issues in CA and 

nationally

Stanford Center for 

Longevity

• Conducts research on 

financial fraud and 

older adults

• Created a financial 

fraud research center 

In collaboration with the 

Financial Industry 

Regulatory Authority 

California District Attorneys 

Association

San Francisco Elder 

Financial Abuse 

Collaboration

• Participants from 

across local 

government and the 

private sector. Goal is 

to conduct innovative 

and comprehensive 

research and to bring 

stakeholders together 

to advocate for 

improved responses to 

elder financial abuse. 

San Francisco

• Multidisciplinary Teams 

—representatives from 

the fields of aging, civil 

law, adult protective 

services, mental health, 

social work, law 

enforcement, and other 

disciplines meet to 

review complex abuse 

cases and to learn 

about service 

resources and 

intervention techniques.

San Bernardino County

• Multidisciplinary 

Teams—a variety of 

groups exist, and they 

discuss issues ranging 

from those specific to 

the District Attorney 

population to limited 

capacity. Teams also 

work on training and 

discuss individual 

cases.

State Law

• CA Financial Abuse 

Reporting Act—

employees of banks 

Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation
Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation

Page 54 GAO-13-110 Elder Financial Exploitation

State 

Efforts to Prevent 

Exploitation by Financial 

Services Providers, 

Power-of-Attorney 

Agents, and Paid in-Home 

Caregivers

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions Responding 

to Exploitation

common scams, and 

unscrupulous sales 

practices that 

specifically target 

seniors

Department of Financial 

Institutions

• Website: provides 

information for 

consumers on 

preventing and 

reporting elder financial 

exploitation,as well as

information for banks 

on reporting 

requirements

• Provides training for 

police investigators

San Francisco District 

Attorney

• Provides training for 

CA mandated reporters

Elder Financial Protection 

Network

• Events and training for 

financial professionals

and credit unions are 

required to report 

suspected financial 

elder abuse to APS or 

law enforcement 

authorities

Financial Elder Abuse 

Roundtable

• Consists of 

Departments of 

Corporations, 

Insurance, Attorney 

General, and Aging. 

The roundtable hears 

from local members 

about issues that are of 

concern and 

determines how the 

state might help.

Illinois Department on Aging

• Volunteer Money 

Management Program 

—a protective service 

for limited income 

seniors who need help 

managing their 

finances

State Law

• Mandatory elder abuse 

reporting for social 

services and health 

care professionals

• Power-of-attorney law 

enhanced to create 

liability for the agent in 

cases of abuse. If an 

agent violates the law, 

they will be required to 

repay what was stolen.

• Mandatory background 

checks for paid inhome caregivers

Department on Aging

• “Be a Savvy Senior” —

publications designed 

to raise older adults’ 

awareness of financial 

exploitation and to 

teach them to look for 

the warning signs

Attorney General

• Fraud alerts —

information on the 

most common scams 

perpetrated against 

seniors

• “When in Doubt, Check 

it Out”—consumer 

fraud hotline to learn of 

any complaints filed 

against a company 

before doing business 

with them

• “Every Cent Counts” —

tips for protecting 

finances of senior 

citizens

Department on Aging

• B*SAFE program to 

train bank personnel on 

how to prevent, detect, 

and report financial 

exploitation

• “Protocol for Law 

Enforcement: 

Responding to Victims 

of Elder Abuse, Neglect, 

and Exploitation” 

 - provides model 

guidelines and 

investigation 

procedures for law 

enforcement responding 

to elder abuse. Protocol 

was created in 

collaboration with the 

Illinois Family Violence 

Coordinating Councils

• “Reporting Elder 

Abuse: What 

Professionals Need to 

Know” —pamphlet to 

raise awareness about 

elder abuse and 

Department on Aging

• Multidisciplinary 

Teams—

representatives from 

law enforcement, 

medical, legal, clergy, 

financial, and mental 

health sectors consult 

on complex cases, 

support case workers, 

and improve 

networking among 

group members

Suburban Elder Justice 

Coalition

• Led by AgeOptions, 

suburban Chicago AAA, 

the coalition works to 

improve coordination 

and cooperation 

between elder abuse 

provider agencies and 

law enforcement.

Statewide

• TRIAD programs—law 

enforcement officials, 
Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation

Page 55 GAO-13-110 Elder Financial Exploitation

State 

Efforts to Prevent 

Exploitation by Financial 

Services Providers, 

Power-of-Attorney 

Agents, and Paid in-Home 

Caregivers

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions Responding 

to Exploitation

• “Just Hang Up” —to 

warn seniors about 

telephone scams

Cook County Sheriff’s 

Department

• Senior Law 

Enforcement Academy 

—trains older adults on 

crime prevention

reporting requirements

Attorney General

• Elderly Service Officer 

Program—40 hours of 

elder abuse training for 

law enforcement 

officers

Department of Financial 

and Professional Regulation 

and Department on Aging

• Training for statechartered bank 

employees—a training 

was developed to 

identify the indicators of 

financial exploitation, as 

well as how to report. 

Compliance will be 

checked for during bank 

examinations.

as well as senior 

community advocates 

and other community 

activists. TRIAD 

activities help 

implement crime 

prevention, education 

and volunteer programs 

for older citizens.

New York NY APS

• Financial management 

—APS receives the 

older adult’s monthly 

income, pays their bills, 

and provides money to 

the older adult for 

incidentals

• Power-of-attorney 

controls—APS can 

require an accounting

of funds from older 

adult’s power-ofattorney agent

Brookdale Center for 

Healthy Aging and 

Longevity at Hunter College

• Daily Money 

Management Services 

—helps older adults 

make financial 

decisions or make 

financial decisions on 

behalf of older adults 

who are no longer able

NYC Department for Aging

• “It’s my Money” game 

created a tool —in 

collaboration with the 

Department of 

Consumer Affairs— 

that can be used to 

help older adults avoid 

financial fraud and 

scams

• Study of prevalence of 

elder abuse in NY 

state, in conjunction 

with LifeSpan and Weill 

Cornell Medical college

Attorney General

• “Smart Seniors” 

publication —a guide 

for older adults to help 

guard against scams 

and prevent elder 

abuse

NY State Office of Children 

and Family Services, 

Bureau of Adult Services

• Training on 

investigating financial 

exploitation for 

protective services 

caseworkers

Weill Cornell Medical 

College Division of 

Geriatrics and Gerontology

• Project on Elder Abuse 

and Neglect—conducts 

research and provides 

training on elder abuse, 

including financial 

exploitation

Brookdale Center for 

Healthy Aging and 

Longevity at Hunter College

• Primary trainer of APS 

workers in NY state

NYC Elder Abuse Center

• Goal is to improve 

professional, 

organizational and 

system responses to 

elder abuse, neglect 

and exploitation 

through collaboration 

and coordination 

among agencies

• Multidisciplinary 

Teams—

representatives from the 

health, mental health, 

public safety, legal, 

victim assistance, and 

social services sectors 

review, discuss, and 

coordinate cases of 

elder abuse; identify 

problems that can be 

brought to the attention 

of others for strategizing 

and intervention; and 

identify research needs
Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation

Page 56 GAO-13-110 Elder Financial Exploitation

State 

Efforts to Prevent 

Exploitation by Financial 

Services Providers, 

Power-of-Attorney 

Agents, and Paid in-Home 

Caregivers

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions Responding 

to Exploitation

State Law

• Revised Power-ofattorney form

• Mandatory background 

checks for paid inhome caregivers

NYPD

• Community outreach at 

senior centers

NYC Department of 

Consumer Affairs

• “Be a Savvy Senior” —

guide for older adults

NYC Elder Abuse Network

• Brings police, district 

attorneys’ offices, 

social service agencies, 

and others together to 

discuss legislation, 

policy, research, and

program planning

Weinberg Center for Elder 

Abuse Prevention

• Emergency shelter for 

victims of elder abuse

District Attorney’s Offices

• Elder Abuse or 

Financial Crimes units 

with staff working 

specifically on elder 

financial exploitation 

Pennsylvania State Law

• Mandatory reporting for 

healthcare 

professionals

• Mandatory background 

checks for paid inhome caregivers

PA Securities Commission

• Investor alerts – a 

collection of tips, 

techniques, and 

advisories for investors 

Attorney General

• Senior Consumer 

Reference Guide —

information on how to 

avoid scams and fraud

• Senior Crime 

Prevention University 

— outreach program to 

make older adults 

aware of common 

scams, to teach them 

how to avoid becoming 

a victim, and to know 

whom to alert when 

they are concerned 

about their safety and 

well-being

• “Safe Seniors” 

Pamphlet —

information for older 

adults on how to 

protect themselves 

from abuse, including 

financial exploitation

• Toll-free senior help 

line

Institute on Protective 

Services at Temple 

University

• Staff at the Institute, 

including a financial 

accountant, provide 

investigative assistance 

to APS and law 

enforcement for elder 

financial exploitation 

cases

• Develops curriculum 

and provides training to 

APS 

Philadelphia Corporation for 

the Aging

• Staff member who only 

works on financial 

exploitation cases

• Training to bank 

employees, local 

prosecutors, and other 

professionals on elder 

financial exploitation

Philadelphia Financial 

Exploitation Task Force

• Collaboration between 

APS, law enforcement, 

and private sector, with 

the goal of promoting

awareness and 

prevention campaigns, 

delivering training, and 

increasing their joint 

capacity to conduct 

focused investigations 

and effectively 

prosecute cases

Statewide

• Elder Abuse Task 

Forces - task forces 

review elder abuse 

cases on a regular 

basis and membership 

may include APS, law 

enforcement, judges, 

clergy, bankers, 

healthcare providers, or 

others
Appendix X: Examples of State and Local 

Activities to Prevent and Respond to Elder 

Financial Exploitation

Page 57 GAO-13-110 Elder Financial Exploitation

State 

Efforts to Prevent 

Exploitation by Financial 

Services Providers, 

Power-of-Attorney 

Agents, and Paid in-Home 

Caregivers

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions Responding 

to Exploitation

Philadelphia Police 

Department

• Outreach at senior 

centers

PA Securities Commission

• Elder Investment Fraud 

and Financial 

Exploitation Prevention 

Program (EIFFE)—

educates medical 

professionals about 

how to spot older 

adults who may be 

particularly vulnerable 

to financial abuse and 

then to refer suspected 

investment fraud 

involving these at-risk 

patients to state 

securities regulators 

and/or to APS

• “Confessions of a 

Scam Artist” 

publication—

information to raise 

awareness

Department of Banking

• “Protect Yourself, 

Protect Your Money”— 

publication includes 

information on 

common scams and 

tips on avoiding scams

Adult Protective Services 

Agencies

• State law grants APS 

access to bank records 

for elder financial 

exploitation 

investigations

PA Securities Commission

• ABCs for APS 

Professionals—

information for APS 

workers on how to 

identify investment 

fraud

Attorney General

• Elder Abuse Unit—

investigates and 

prosecutes elder 

financial exploitation

Philadelphia Police 

Department

• Crimes Against Retired 

and Elderly Unit— 

investigates crimes 

affecting older adults

SeniorLAW Center

• Provides legal 

assistance to senior 

crime victims

Source: GAO interviews and review of documents from California, Illinois, New York, and Pennsylvania.
Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and 

Respond to Elder Financial Exploitation

Page 58 GAO-13-110 Elder Financial Exploitation

Efforts to Prevent 

Exploitation by 

Financial Services 

Providers, Power-ofAttorney Agents, and 

Paid in-Home 

Caregivers 

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions 

Responding to 

Exploitation 

AARP

AARP is a nonprofit, 

nonpartisan organization, 

with a membership of 

more than 37 million, that 

helps people age 50 and 

above have 

independence, choice, 

and control in ways that 

are beneficial to them 

and society as a whole.

Free Lunch Monitor 

Program

• AARP asks 

members to send 

them invitations 

they receive to free 

lunch seminars that 

sell investment 

products. Members 

also attend and 

report back to 

AARP on the 

specific investment 

offers. AARP has 

compiled 

information on the 

trustworthiness of 

these investment 

sales pitches.

Protecting Your Assets 

Project

• Project provides basic 

tips on avoiding fraud 

to AARP members, 

including email blasts 

and website links for 

additional information

No Free Lunch Program

• Provides information 

on responding to high 

pressure sales tactics 

on AARP’s website, as 

well as information on 

senior financial advisor 

designations

Research Projects Related 

to Elder Financial 

Exploitation

• AARP has conducted 

several research 

projects related to 

elder financial 

exploitation including 

studies of:

• personality traits of 

fraud victims and 

effective prevention 

messages, 

• effective outreach 

activities for investor 

fraud victims, 

• diminished financial 

capacity of older adults 

and implications for the 

financial services 

industry, 

• preventing the use of 

misleading senior 

designations, 

• power-of-attorney 

abuse and what states 

can do about it,

MoSafe Program

• In conjunction with 

the Missouri 

Bankers 

Association, the 

AARP Missouri 

state office 

developed a training 

program for bank 

clerks on financial 

exploitation

Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and Respond 

to Elder Financial Exploitation
Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and 

Respond to Elder Financial Exploitation

Page 59 GAO-13-110 Elder Financial Exploitation

Efforts to Prevent 

Exploitation by 

Financial Services 

Providers, Power-ofAttorney Agents, and 

Paid in-Home 

Caregivers 

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions 

Responding to 

Exploitation 

and

• background checks 

and other screenings 

for home care 

providers

American Bar 

Association

A voluntary professional 

organization. The mission 

of the American Bar 

Association Commission

on Law and Aging is to 

strengthen and secure 

the legal rights, dignity, 

autonomy, quality of life, 

and quality of care of 

elders.

Research Projects Related 

to Elder Financial 

Exploitation

• Several research 

projects related to 

elder financial 

exploitation have been 

conducted, including 

studies of:

• state APS laws and 

types of elder abuse, 

• bank employees and 

their ability to report 

elder financial 

exploitation, 

• court-focused elder 

abuse initiatives, and

• elder abuse registries 

Continuing Legal 

Education Seminars

• Webinars on topics 

related to elder 

abuse

American Bankers 

Association

Represents banks of all 

sizes and types and is 

the voice for the nation’s 

banking industry and its 

employees

Protecting the Elderly From 

Financial Abuse Pamphlet

• Pamphlet is designed 

for older adults and the 

general public. It 

includes information on 

signs of financial 

abuse, protecting from 

financial abuse, and 

what to do if someone 

suspects financial 

abuse. 

Information for members

• Shares information 

with members on 

how to identify elder 

financial exploitation

• Provides information

via conferences and 

phone briefings to 

its members on 

federal bank privacy 

laws, encouraging 

members to report 

suspicious activity

Frontline Training for 

Bank Employees

• Consumer 

protection and 

privacy training is 

intended for frontline 
Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and 

Respond to Elder Financial Exploitation

Page 60 GAO-13-110 Elder Financial Exploitation

Efforts to Prevent 

Exploitation by 

Financial Services 

Providers, Power-ofAttorney Agents, and 

Paid in-Home 

Caregivers 

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions 

Responding to 

Exploitation 

bank employees. 

Training includes 

various aspects of 

consumer 

protection, including 

elder financial 

exploitation.

Bank Compliance 

Magazine article JulyAugust 2011 edition

• In a magazine 

distributed to banks, 

types of elder 

financial 

exploitation, why 

older adults are 

particularly 

vulnerable, the role 

of banks, and 

relevant state and 

federal laws were 

described

National Adult 

Protective Services 

Association

A national non-profit with 

over 500 members in all 

fifty states. Provides state 

and local Adult Protective 

Services program 

administrators and staff 

with a forum for sharing 

information, solving 

problems, and improving 

the quality of services for 

victims of elder and 

vulnerable adult abuse.

Research Projects Related 

to Elder Financial 

Exploitation

• Currently conducting a 

baseline survey of 

state APS programs

• Report on state APS 

responses to financial 

exploitation of 

vulnerable adults

National Adult Protective 

Services Resource 

Center

• Runs the Resource 

Center, which is 

funded by the 

Administration on 

Aging

National Conference

• Hosts a conference 

for APS 

professionals and 

several sessions are 

usually dedicated to 

elder financial 

exploitation

Webinars

• Hosts webinars on 

various topics 

related to elder 

abuse for APS 
Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and 

Respond to Elder Financial Exploitation

Page 61 GAO-13-110 Elder Financial Exploitation

Efforts to Prevent 

Exploitation by 

Financial Services 

Providers, Power-ofAttorney Agents, and 

Paid in-Home 

Caregivers 

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions 

Responding to 

Exploitation 

professionals

Creating APS Core 

Training

• Working with 

California officials to 

create core 

competencies for 

APS workers, which 

would include 

financial 

exploitation, with a 

goal of creating 

national core 

training for APS 

workers 

Financial Industry 

Regulatory Authority

The largest independent 

regulator for all securities 

firms doing business in 

the United States. Its 

mission is to protect 

America’s investors by 

making sure the 

securities industry 

operates fairly and 

honestly.

Collects investor 

complaints

• Investors are able 

to make complaints 

via its website, 

phone, fax, or mail.

Investor Alerts

• Disseminates 

information about 

scams, trends, or new 

financial products

Research Projects Related 

to Elder Financial 

Exploitation

• Conducted several 

research projects 

related to elder 

financial exploitation, 

including studies of:

• Investment fraud

• National Financial 

Capability Study

• Senior Investor 

Literacy and Fraud 

Susceptibility

• Senior Fraud Risk

• Senior Financial 

Advisor Designations

Collaboration with 

federal and state 

regulators

• Works closely with 

the Securities and 

Exchange 

Commission on 

investor education 

and examinations

• Works with state 

securities regulators 

on investor education 

campaigns

Collaboration with other 

non-governmental 

organization

Together with the 

Stanford Center on 

Longevity, founded a 

financial fraud research 

center

Investor Protection 

Trust

A nonprofit organization 

devoted to investor 

education. The primary 

mission is to provide 

Elder Investment Fraud 

and Financial 

Exploitation Prevention 

Program 

• The program 

educates medical 

Research Projects Related 

to Elder Financial 

Exploitation

• Surveyed older adults 

and their families about 

handling personal 
Appendix XI: Examples of Non-Governmental 

Organization Activities to Prevent and 

Respond to Elder Financial Exploitation

Page 62 GAO-13-110 Elder Financial Exploitation

Efforts to Prevent 

Exploitation by 

Financial Services 

Providers, Power-ofAttorney Agents, and 

Paid in-Home 

Caregivers 

Efforts to Educate and 

Inform Older Adults and 

the General Public

Efforts to Provide 

Information to and 

Enhance Expertise for 

Professionals 

Responding to 

Exploitation 

Efforts to Foster 

Collaboration among 

Institutions 

Responding to 

Exploitation 

independent, objective 

information needed by 

consumers to make 

informed investment 

decisions.

professionals on 

how to spot older 

Americans who 

may be particularly 

vulnerable to 

financial abuse, 

particularly those 

with mild cognitive 

impairment, and 

then to refer 

suspected 

investment fraud 

involving these atrisk patients to 

state securities 

regulators and/or to 

local APS 

professionals.

finances, current 

financial conditions, 

and experiences with 

financial fraud or 

abuse.

• Surveyed experts 

about elder financial 

exploitation.

National Call-in Day: 

Protecting Elders from 

Financial Abuse

• Hosted a call-in day, in 

collaboration with other 

organizations, for older 

adults and their 

families to receive free 

advice and guidance 

on protecting against 

investment swindles 

and financial abuse

Financial Services 

Roundtable, BITS

The mission of the 

Financial Services 

Roundtable is to protect 

and promote the 

economic vitality and 

integrity of its members 

and the United States 

financial system. BITS 

addresses issues at the 

intersection of financial 

services, technology and 

public policy, such as 

critical infrastructure 

protection, fraud 

prevention, and the safety 

of financial services. 

Older Americans Financial 

Abuse Prevention Working 

Group Pamphlet

• Contains fraud 

prevention tips for 

consumers and for 

organizations working 

with older adults 

BITS Fraud Prevention 

Toolkit

• Information for 

banks on the role of 

financial institutions 

in preventing and 

responding to elder 

financial 

exploitation, red 

flags and types of 

offenders and 

scams, and the role 

of APS

Collaboration with state 

and local governments 

and other nongovernmental 

organizations

Older Americans 

Financial Abuse 

Prevention Working 

Group

Source: GAO interviews and information collected on organization websites.
Appendix XII: Criminal Background Check 

Requirements for In-home Caregivers in 

Selected States

Page 63 GAO-13-110 Elder Financial Exploitation

State 

Criminal Background 

Checks Mandatory 

or Discretionary? 

Checks for Publicly 

Funded Care Only or 

Publicly and Privately 

Funded Care? 

Type of 

Background 

Check

Conditional 

Employment 

Allowed? a Disqualifying Offenses

California Discretionary Publicly & privately 

funded care

State and federal State does not 

specify

Offenses that are against 

dependent or vulnerable 

individuals or fraud-related 

Illinois Mandatory Publicly & privately 

funded care

State only Yes Homicide; other violent, 

sex-related, drug-related, 

fraud-related; and property 

offenses

New York Mandatory Publicly & privately 

funded care

State and 

sometimes 

federal

Yes Homicide; other violent, 

sex-related, drug-related, 

and fraud-related offenses; 

and offenses against 

dependent or vulnerable 

individuals

Pennsylvania Mandatory Publicly & privately 

funded care

State and 

sometimes 

federal

Yes Homicide; other violent, 

sex-related , drug-related, 

and fraud-related offenses; 

and offenses against 

dependent or vulnerable 

individuals

Source: AARP Public Policy Institute. (September 2010) Safe at Home? Developing Effective Criminal Background Checks and Other 

Screening Policies for Home Care Workers

Note: Information is as of December 2008.

a Conditional employment occurs when in-home caregivers are allowed to begin working before 

background checks are complete.

Appendix XII: Criminal Background Check 

Requirements for In-home Caregivers in 

Selected States
Appendix XIII: Resource Centers Supported by 

the Administration on Aging

Page 64 GAO-13-110 Elder Financial Exploitation

Name Intended Users Information and Services

National Center on 

Elder Abuse 

National, state, and local professionals working with 

victims of elder mistreatment, including APS 

professionals, state and federal agencies, law 

enforcement, legal professionals, health care 

professionals, domestic violence networks, 

community-based organizations, elder rights 

advocates

Public policymakers

Researchers

General public

Disseminates news items related to elder abuse

Operates a listserv for professionals

Provides information about promising practices and 

interventions

Provides a training library

Funds research

National Adult 

Protective Services 

Resource Center 

Adult Protective Services professionals nationwide Disseminates a monthly newsletter

Maintains an APS-specific listserv

Publishes brief descriptions of recent applicable research

Holds regular webcasts

Collects and compiles detailed information about APS 

throughout the country

Provides information to state and local APS programs to 

facilitate implementation of identified best practices and 

research findings

National Legal 

Resource Center 

Professionals involved in protecting the rights of 

older persons, including:

Providers of legal assistance, including senior legal 

helplines

State and local APS professionals

Elder rights advocates

Disseminates information on a wide range of legal issues 

affecting older adults

Training on legal issues

Technical assistance on the provision of legal services to 

older adults

Case consultation, including on elder financial 

exploitation cases 

Source: GAO analysis of information provided by NCEA, National Adult Protective Services Resource Center, and National Legal 

Resource Center.

Appendix XIII: Resource Centers Supported 

by the Administration on Aging
Appendix XIV: Example of a Letter Promoting a 

Fraudulent Sweepstakes Scheme

Page 65 GAO-13-110 Elder Financial Exploitation

Appendix XIV: Example of a Letter 

Promoting a Fraudulent Sweepstakes 

Scheme 
Appendix XV: Total Number of FTC Consumer 

Sentinel Network Complaints by Source, CY 

2011

Page 66 GAO-13-110 Elder Financial Exploitation

Source Number of Complaints Percent of Total

Complaints made directly to the FTC, by individuals and othersa 788,576 43%

Better Business Bureaus 416,520 23%

Internet Crime Complaint Centerb 302,381 17%

Western Union Money Transfer 54,657 3%

Canadian Anti-Fraud Centre 39,260 2%

Publisher’s Clearinghouse 37,311 2%

Others (such as state and local agencies and U.S. Postal Inspectors) 174,375 10%

TOTAL 1,813,080 100%

Source: FTC

a

These complaints may be made by phone, mail, or on the FTC’s website.

b

The Internet Crime Complaint Center, co-sponsored by the FBI and the National White Collar Crime 

Center, collects internet-related criminal complaints and aims to further research, develop, and refer 

these complaints to appropriate federal, state, local, and international agencies.

Appendix XV: Total Number of FTC 

Consumer Sentinel Network Complaints by 

Source, CY 2011
Appendix XVI: Comments from the Consumer 

Financial Protection Bureau

Page 67 GAO-13-110 Elder Financial Exploitation

Appendix XVI: Comments from the 

Consumer Financial Protection Bureau 
Appendix XVI: Comments from the Consumer 

Financial Protection Bureau

Page 68 GAO-13-110 Elder Financial Exploitation
Appendix XVI: Comments from the Consumer 

Financial Protection Bureau

Page 69 GAO-13-110 Elder Financial Exploitation

 
Appendix XVII: Comments from the 

Department of Health and Human Services

Page 70 GAO-13-110 Elder Financial Exploitation

Appendix XVII: Comments from the 

Department of Health and Human Services
Appendix XVII: Comments from the 

Department of Health and Human Services

Page 71 GAO-13-110 Elder Financial Exploitation
Appendix XVIII: GAO Contacts and Staff 

Acknowledgements

Page 72 GAO-13-110 Elder Financial Exploitation

Kay E. Brown, (202) 512-7215 or brownke@gao.gov.

In addition to the contacts named above, Clarita Mrena, Eve Weisberg, 

Andrea Dawson, and Brittni Milam made significant contributions to this 

report, in all aspects of the work. Also contributing to the report were 

James Bennett, Gary Bianchi, Jason Bromberg, Alicia Cackley, Paul 

Desaulniers, Holly Dye, Eileen Larence, Jean McSween, Chris 

Morehouse, Claudine Pauselli, Almeta Spencer, Kate Van Gelder, and 

Craig Winslow.

Appendix XVIII: GAO Contacts and Staff 

Acknowledgements 

GAO Contacts:

Staff 

Acknowledgements: 
Related GAO Products

Page 73 GAO-13-110 Elder Financial Exploitation

Incapacitated Adults: Oversight of Federal Fiduciaries and CourtAppointed Guardians Needs Improvement. GAO-11-678. Washington, 

D.C.: July 22, 2011.

Elder Justice: Stronger Federal Leadership Could Help Improve 

Response to Elder Abuse. GAO-11-384T. Washington, D.C.: March 2, 

2011

Elder Justice: Stronger Federal Leadership Could Enhance National 

Response to Elder Abuse. GAO-11-208, Washington, D.C.: March 2, 

2011

Older Americans Act: More Should Be Done to Measure the Extent of 

Unmet Need for Services. GAO-11-237. Washington, D.C.: February 28, 

2011.

Consumer Finance: Regulatory Coverage Generally Exists for Financial 

Planners, but Consumer Protection Issues Remain. GAO-11-235. 

Washington, D.C.: January 18, 2011.

Guardianships: Cases of Financial Exploitation, Neglect, and Abuse of 

Seniors. GAO-10-1046. Washington, D.C.: September 30, 2010.

Guardianships: Little Progress in Ensuring Protection for Incapacitated 

Elderly People. GAO-06-1086T. Washington, D.C.: September 7, 2006.

Results-Oriented Government: Practices That Can Help Enhance and 

Sustain Collaboration among Federal Agencies. GAO-06-15. Washington, 

D.C.: October 21, 2005.

Guardianships: Collaboration Needed to Protect Incapacitated Elderly 

People. GAO-04-655. Washington, D.C.: July 13, 2004.

Related GAO Products

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