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#2019780 - 06/11/15 02:12 PM SAR on Elder Abuse
Anonymous
Unregistered

We are going to file a SAR in the next few days on an elder abuse case, but are contacting the police about it today.

Are we able to share with the police today what we feel may be the fraudulent transactions? Once the SAR is filed, they are entitled to any supporting docs, but how about before that?

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#2019811 - 06/11/15 02:59 PM Re: SAR on Elder Abuse [Re: Anonymous]
Anonymous
Unregistered

bump

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#2019837 - 06/11/15 03:38 PM Re: SAR on Elder Abuse [Re: Anonymous]
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
After you file the SAR, the answer is based on federal law. Before you file the SAR, the answer is based on state law.

Please wait at least a couple of days to "bump" a post; your audience is changing constantly.
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#2020010 - 06/11/15 10:05 PM Re: SAR on Elder Abuse [Re: Anonymous]
Anonymous
Unregistered

Do you have the capability to make a referral to an entity such as the Division of Aging Services in your state? We have done this without providing any documents, etc., just a referral for them to talk with the person about who is doing what for them.

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#2020122 - 06/12/15 04:09 PM Re: SAR on Elder Abuse [Re: Anonymous]
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,713
New York City
^ That's the way to go. Contact Adult Protective Services or whatever it's called within the state that the customer is located.
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#2020258 - 06/12/15 11:03 PM Re: SAR on Elder Abuse [Re: Anonymous]
BetsyS Offline
Gold Star
Joined: Jun 2009
Posts: 468
To me filing a SAR on Elder Abuse has nothing to do with reporting it to police or any other state authority. As to sharing information, there may be provisions in your state law; ours has a safe harbor for reporting Elder Abuse.

You also may want to take a look at the "Interagency Guidance on Privacy Laws and Report Financial Abuse of Older Adults": http://www.occ.gov/news-issuances/news-releases/2013/nr-ia-2013-148a.pdf Section 502(e) of GLBA provides a variety of exceptions which permit an institution to disclose information about consumers to local, state or federal agencies to protect against or prevent actual or potential fraud, unauthorized transactions.

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