Alerted from Lending dept regarding a HELOC Appl (I'm in BSA) that we suspect elder financial exploitation. Cash out purpose letter rec'd states gifting $13,000 each to two daughters (max non-tax gift amt) and also assigning one daughter as POA for closing.

Lending experts - how can we decline the loan? the borrower has limited fixed income, but does qualify. Is there a basis for denying a loan for 'suspected fraud' or 'possible elder abuse'?

The elder/borrower has no current relationship with our bank and the appl came in from a broker.

Please help!