Consumer complaint received 2021-05-19
Product: Money transfer, virtual currency, or money service — International money transfer
Issue: Fraud or scam — 
Company: PNC Bank N.A. (PA)

PNC Bank failed to Exercise Due Diligence to protect elderly customers such as myself who are the prime targets of scammers from using their favorite weapon of the international money transfer to steal our money. 
XXXX PNC XXXX - XXXX, XXXX and XXXX - mistakenly approved a scam, and sent my money to XXXX. 

My Complaint presents the Narrative, followed by Questions. 

The Narrative I am a XXXX minister who serves the XXXX and their families as a hospice chaplain. 
God reveals grace in this work, and sometimes I am blessed to see it. 

The PNC Bank seems to have bought into and abetted a scam which took all my money. 

The Police Report begins : For 55 years in ministry, I have served the poor, and for the last ten served the XXXX. 
I was ordained with the charge that the way to XXXX is down. I always lived within my means, and was content. 
Two months ago I had assets of {$24000.00} in checking and {$5000.00} in my tithing account, with no debt or savings or investments. 
Now, I have {$240.00} in checking and {$550.00} tithing, with debts of {$29000.00}. 
My identity had been stolen and used in two large drug deals in Texas. This fact was developed into a scam by five different criminals who called me impersonating law enforcement officers from different national and local law enforcement bodies. 

The crooks applied with great intensity XXXX unfamiliar emotions : fear and greed. Fear threatened prison : an arrest warrant has already been issued against you for the drug sales, but its enforcement is being held back by your case officer. Greed promised fortune : compensation in proportion to the size of the drug sales ; a U.S. Treasury check for {>= $1,000,000}. 

A Controller, impersonating a case officer with the U.S, Customs and Border Patrol, directed my every move. He sent me first to the XXXX bank where I had my checking account to apply for an international money transfer. The Local Manager there explained the duty of Due Diligence. Scammers take the elderly as their prime targets, and use international money transfers as their favorite weapon. Unless I could prove a real emergency, he had to say No. The Conrtroller directed me to withdraw my money and look for an easier bank.

The Controller then sent me to a XXXX XXXX bank. The Local Manager there repeated his duty about prime target, favorite weapon and Due Diligence to say No. He added two core questions : Do you have their home address? 
Have you met them in person? 
A scammer would risk being caught by answering either. A No answer to the two core questions guaranteed it was a scam, and he would have to say No. He added that they blocked love scams as well as money scams.

The Controller then sent me to a PNC Bank, where I deposited my money.

1. PNC Bank, apparently buying into the scam, immediately assigned a High Net Worth Advisor to help me with the expected {$9.00} million dollar deposit. XXXX XXXX XXXX can be reached at XXXX. Perhaps the large deposit made them overeager and careless.

2. PNC Bank barely went through the motions of Due Diligence. at the Local, Regional and National levels. 
I went into the XXXX XXXX office of PNC, and told my phony story about investing in palliative care in XXXX. 
The Local Manager, a young woman, responded to my relating personally by talking about herself as she typed the form. I dont recall her even reading questions from the application form. She responded from happy emotion. She failed even to state the duty of Due Diligence : to protect elderly customers who are prime targets from international money transfers which are the favorite weapon, or warn me that she would have to say No unless I could prove an emergency. She did not ask any questions to challenge my story.

The Regional Manager, an older woman who happened to be in that branch that day, emerged from her neighboring office where she appeared to have heard the initial proposal. She seemed to join in the pleasant emotion. She also failed to state the purpose of Due Diligence, requiring me to prove an emergency. She even mentioned - but did not ask - one of the core questio
ns, stating that if you do not know their home address that proves its a scam.

The National Manager, a wary but tired-sounding man with whom I spoke by phone, asked several exploratory questions and did ask one of the core questions : Have you met in person? I answered honestly - No.

He appeared not to take my No seriously. He did not ask the other core question : Do you know their home address? He rambled through a few odd questions, then said Yes to the scam.

3. All three PNC Managers failed to challenge my story. None asked if I had a business plan, or even knew whether this venture had been tried before.

4. All three PNC Managers failed to state their duty of Due Diligence : to protect el
derly customers like me who are prime targets, from international money transfers which are favorite weapons, because Due Diligence required them to say No unless I proved an emergency.

5. All three PNC Managers failed to use the core questions that surely expose a scam. 6. All three PNC Managers failed to do the math that exposes a scam. A venture investment would take only a small portion of the elderly persons funds. A scam would take a large portion. This transfer took 88 % of all my funds. Red Flag! Scam!
7. All three PNC Managers failed to see the danger and mistakenly said Yes to the scam. 

PNC Bank sent all my money to XXXX. Then they closed my account to cover up their mistakes. 

I am pleading with PNC to own responsibility for their mistakes and restore my funds. 

PNC Bank will probably continue their cover up unless held accountable in the court of public opinion or by regulatory agencies. 


The Questions The Consumer Financial Protection Bureau XXXX " CFPB '' XXXX issued best practices to prevent elder financial abuse. 
Develop, implement and maintain internal protocols and procedures for protecting elder account holders. These measures should include Training and Reporting.

Banks should train employees regularly and frequently. Training programs should include, at a minimum : ( a ) adoption of a comprehensive and multifaceted definition of elder financial exploitation ; ( b ) categorical descriptions of indicators of potential elder financial exploitation ( e.g., transaction patterns, behavioral changes, theft and coercion scenarios, etc. ) ; and ( c ) preventative measures and clearly defined action steps for internal responses, hierarchical reporting, law enforcement reporting, and the filing of detailed Suspicious Activity Reports. Report all cases of suspected exploitation. Mandatory and voluntary reporting of elder abuse are governed by state laws. ( boldface added ) Questions concerning PNC Banks policy.

Question # 1 Definition 1A What is PNC Banks comprehensive and multifaceted definition of elder financial exploitation?

1B In what documents is it found?

1C How is it used to train Managers to exercise Due Diligence?

Question # 2 Indicators 2A List specifically all the indicators you train your managers to look for in exercising their required Due Diligence to protect elderly customers from scams.

2B Do you require your managers during Due Diligence to ask the two core questions, which scammers can not answer without getting caught : First, Have you met them in person? 
Second, Do you know their home address?

If not, why not?

2C How do you monitor their performance to ensure they are asking the core questions?

Question # 3 Preventative measures and action steps 3A. Describe in detail what preventative measures you use to avoid failing Due Diligence?

3B. Quote from your policies what specific action steps you take to avoid failing Due Diligence? 

Question # 4. In the case of Rev. XXXX - which went beyond Suspicious Activity to Proven Fraud - provide copies of all Reports made by PNC Bank XXXX. internally, XXXX to law enforcement, and XXXX to all relevant regulatory state agencies. 

Questions concerning PNC Banks performance. 
Failure to exercise XXXX XXXX occurs when Managers approve scams that exploit elderly customers. 

Question # 5 Concerning the three managers who failed to exercise Due Diligence 5A. Did the Local Manager who failed Rev, XXXX ask the two core questions?

5B. Did the Regional Manager who failed Rev. XXXX ask the XXXX core questions? 
XXXX. Did the National XXXX who failed Rev, XXXX ask the two core questions?

Question # 6 Concerning PNC Banks corrections Provide copies of all internal communications to those three Managers showing PNC Banks effort to correct their perform
ance.

Question # 7 Concerning acceptable failure rates During the past year among PNC Banks Managers in XXXX County 7A. How many times did Managers fail to exercise Due Diligence by saying Yes to scams. ( This includes scams that were eventually blocked : for example, if the Local and Regional Managers said Yes but the National Manager said No, that counts as two failures. ) 7B. How many scams involving International Money Transfers actually went through due to the failure of all three Managers? 
XXXX. How many victimized elderly customers a year does PNC Bank consider acceptable? 
XXXX. What has PNC Bank done to compensate elderly victims victimized when PNC Banks failures in Due Diligence cost them dearly - perhaps even their life savings?

Question 8 Concerning PNC Banks compliance with the standards of the American Bankers Association.

8A. Provide copies of all Due Diligence Reports filed with the ABA in the past year related to your duty of Due Diligence in protecting elderly customers from scams using i
nternational wire transfers, or sudden purchase of gift cards.

8B. Did PNC Bank offer Rev. XXXX a Second Set of Eyes as recommended? 

The XXXX XXXX XXXX sets standards for Due Diligence. 
The XXXX XXXX XXXX also offers XXXX Due Diligence Reports and Information Sheets ( Available to Bankers ) https : XXXX XXXX XXXX XXXX XXXX XXXX XXXX set of eyes protects elderly customers from scams. 

The Foundations XXXX XXXX XXXX XXXX noted XXXX XXXX and other seniors 65 and above account for XXXX percent of all deposits. Larger financial institutions, like XXXX  XXXX XXXX and XXXX XXXX ask customers for a trusted contact in large to give seniors a second set of eyes to protect them from fraud. https : XXXX? XXXX