The IDFPR and DoA must develop standards for what's expected of the banks.
Here's what the Illinois Bankers Association published on the question:
Financial Exploitation of the Elderly
Senate Bill 3267 (Public Act 96-1103, effective July 19, 2010) requires the Department on Aging (DoA) and the Illinois Department of Financial and Professional Regulation (IDFPR) to develop "minimum standards" that state-chartered financial institutions must use to train frontline employees on recognizing financial exploitation of the elderly. IDFPR will retain sole visitation and enforcement authority for this training and must provide bi-annual reports to the DoA containing aggregate statistics on these training programs.
As introduced, SB 3267 would have imposed mandatory reporting requirements on financial institutions. The IBA testified in committee against the original bill. As a result of our opposition, the enacted legislation represents a hard fought compromise between the IBA and our financial institution industry coalition and the DoA, the City of Chicago, and the Illinois Association of Area Agencies on Aging.