I read the Advisory that the CFPB issued yesterday on Elder Financial Exploitation: http://files.consumerfinance.gov/f/20160...xploitation.pdf

Many of the recommendations we are doing in some form; however, one that sticks out to me is the recommendation that banks provide a plain language consent form at account opening, and periodically thereafter (maybe they to replace some of the post office's lost income from annual privacy notices), for customers to consent to disclosure of account information to a named 3rd party if the bank ever suspects financial exploitation. The customer could revoke and replace these individuals. While I can see situations where this would be beneficial to have (such as no joint account holder on an elderly customer's account), I think it would be very difficult to implement, hard to maintain, would be needed very rarely, and many customers would find it insulting.

Is anyone doing anything like this now, and if not do you plan to?

While this may be a good idea in many circumstances this can be a huge disaster in others.

When the customer is alone on the account and receives such a mailing. The customer may ask bank for instructions on who to pick and may think that this person should also additionally grant power of attorney to said person who cleans him out. The blame will be on the bank even if the bank does not give such instructions. While on the surface may be far fetched many of us can attest to this happening without the prod from the CFPB.

"and many customers would find it insulting" yep

All I did was add it to the topic list for our next Compliance Committee meeting. I am already imagining the reception.

Once again, Pollyanna (the CFPB) is well meaning, but way short on comprehension. A "consent" form signed by the consumer would protect the bank, not the consumer. As suggested, most of those who exploit the elderly are from the same gene pool; e.g. the consent form says you can tell the party who's doing the stealing? Personally, I would rather make a disclosure to a state agency than an individual.

On the other hand, assume the customer has been offered the chance to sign the consent form and has declined. Should the bank consider that a tacit prohibition against disclosure?

If a bank wants to "disclose" something just tell everyone opening an account (18 to 88) what the state's laws on disclosure of financial exploitation are

Yes, it's hard to picture what the wording on the form would look like.

Signing this form gives the bank the option to discuss the account activity with the named party, however the bank may deem this not in your best interests and will report to a state agency instead. Assuming we notice the activity, that is.

Once again, Pollyanna (the CFPB) is well meaning,

Clearly you jest.

My rare attempt at being gracious...

Bless their hearts!