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Vulnerable Customers Presented by Paul Bonello
ANZ Banking Group
NATIONAL CONFERENCE & EXHIBITION 2014
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Silver Sponsor Bronze SponsorRisk Manager of the Year
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National Conference & Exhibition 2014
Vulnerable customers and Elder abuse
Today I will run through:
• Background ANZ Journey
• Financial/Elder Abuse
• Cognitive Impairment
• What can be done
• Training Video
• 2 Case Studies
• Dementia Stats
National Conference & Exhibition 2014
Vulnerable customers and Elder abuse
Background
Banks have a responsibility to ensure that their customers can conduct their banking safely and securely. Some people may haverestricted physical or mental capacity in which to conduct their banking activities and require additional support.
In 2013 a working group was formed at ANZ to implement a process to address the growing issue of Vulnerable Customers andElder Abuse.
Representatives from Risk, Legal, Customer Advocate team, Complaints, Retail and Operations worked together to implement aprocess to enable Frontline staff to escalate cases where they suspect Cognitive Impairment or abuse.
We engaged with the Office of the Public Advocate, Senior Rights Victoria and other State Advocate bodies to understand theirprocess for escalation.
This was further emphasized when the ABA issued Industry guidelines in June 2013 advising Institutions on protecting vulnerablecustomers from potential financial abuse.
The guideline is voluntary and has been developed with input from and agreed with member banks. Member banks are encouragedto follow this industry guideline and incorporate it into their internal process, procedures and policies.
National Conference & Exhibition 2014
Vulnerable customers and Elder abuse
What is financial / elder abuse?
Financial abuse can take many forms and it usually consists of a number of actions over a period of time, rather than a single event. A ‘financial abuser’ can be someone you hardly know or someone you have known for many years.
They could be family members, friends, acquaintances or strangers who befriend you. They may also be professionals or caregiversemployed to help you.
A financial abuser is anyone who manipulates, threatens, pressures or otherwise influences you to gain access to your money,property or other valuables. Abusers often take advantage of the trust or power they are given.Examples of financial / elder abuse includes and is not limited to:
• Taking money or property
• Forging an older person's signature
• Getting an older person to sign a deed, will, or power of attorney through deception, coercion, or undue influence
• Using the older person's property or possessions without permission
• Telemarketing scams. Perpetrators call victims and use deception, scare tactics, or exaggerated claims to get them to send money.
They may also make charges against victims' credit cards without authorization (i.e. Nigerian money scam, online dating, South
African diamond scam)
National Conference & Exhibition 2014
Vulnerable customers and Elder abuse
National Conference & Exhibition 2014
Vulnerable customers and Elder abuse
Financial abuse transition points
Risk factors for financial abuse include transition points in an older person’s life, such as:
• Widowhood for a woman with little or no experience with financial matters
• When an older person’s health is changing and he/she begins relying on new-found male or female friends
• When cognitive capacity is starting to decrease
• When a person becomes dependent on others to aid with banking or shopping
Some key indicators of evidence of financial / elder abuse
• Increase in withdrawals from bank accounts or transfers between accounts to third parties of high value
• Unpaid bills, eviction notices, or notices to discontinue utilities (i.e. power, water)
• Suspicious signatures on cheques / withdrawal slips or other documents
• New “best” friends
• Family members or third parties (i.e. carers, church members) attending the branch with the customer coercing / influencing them to withdraw large amounts of funds
Common perpetrators
• Family members, including children, grandchildren, or spouses. (They may for example have substance abuse, gambling, or financial problems)
• Unscrupulous professionals or tradesmen who may overcharge for services or products (i.e. cutting lawns, plumbing or roofing issues)
• Use their positions of trust or respect to gain confidence of the vulnerable person.
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
Who is at risk?
• People lacking mental capacity or vulnerable (i.e. suffering from Dementia or other cognitive impairment)
• Other social or economic conditions that may impact their ability to judge and make decisions.
This can be extend to and is not limited to;
• Loneliness
• Recent losses
• Lack of familiarity with financial matters
• Having family members who are influential on their financial matters
Some key indicators of evidence of cognitive impairment
• Forgetting recent banking transactions
• Difficulty deciding the type of transaction to conduct
• Inappropriate behaviour or responses ( i.e. frustrated, agitated, confused)
• Not understanding what staff are saying to them
• Difficulty explaining their banking requirements
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
What can we do?
The key to dealing with this issue is to know the signs and escalate to the right areas who can assist the frontline staff in dealing
with this situation. We now have a high level process to escalate and assist customers at risk.
3 key areas we can escalate to include:
• External Investigations
• Customer Advocate Team
• Relevant State body
Scenario CriteriaIn dealing with a customer or customer representative Branch staff member
is concerned with unusual activity on their accounts or unusual behaviour is
being displayed by the customer
Suspect
Cognitive Impairment
Suspect
Financial
Abuse
Judgement – Determine
if escalation required
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
“Is it Dementia” support video.
Alzheimer’s Australia has created two short videos targeting the banking and finance industry. These
are located on the Alzheimer's Association website under “Is it dementia”
These videos illustrate what frontline staff encounter and provide assistance and advice on:
• what to expect
• how to respond and
• what pro-active measures you could put in place to assist your customers
http://isitdementia.com.au/banking.html
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
Reporting Financial Abuse
Staff should attempt to learn the reason for large or frequent withdrawals and they should also check to see what documentation isHeld (e.g. Power of Attorney, Administration Order or third party authority).
When in doubt the key thing to do is escalate to the relevant areas who are skilled to deal with this Issue. This includes Legal, Risk and External Investigations.
Dealing with customers with Dementia and /or other Cognitive Impairments
If a customer displays signs of dementia, or other cognitive impairment where you believe they are unable to manage their account, staff are encouraged to;
• Stay calm and speak to the customer in a soft tone voice
• Request the customer speak to their manager or supervisor preferably in an office or a quiet location within the branch
• If they remain concerned, investigate if the customer has a Power of Attorney, Administrator / Guardian, or a family member that can be contacted.
Following the discussion, if the customer does not have a Power of Attorney, Administrator / Guardian, or family member you can contact, and they still have concerns about their ability to manage their accounts, report concerns via email to the CustomerAdvocate Team for further investigation.
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
Case Study 1
What would you do?
• The customer, Ms D, is aged in her nineties and has significant funds held in Term Deposit.
• Her Son, Mr D accompanies her to the branch advising the staff that she is now living with him and he is her primary carer
• Mr D later attends the branch with his mother and a POA signed by his mother is provided.
• Mr D advises the branch that he would like to withdraw $300,000 to invest funds for his Mother
Case Study 2
• The customer, Ms B, is aged in her sixties and has funds held in a Term Deposit and various Access accounts.
• Her Son and Husband advise the bank that she has been moved to a Nursing home. Furthermore they sell the family home with the proceeds of the sale going solely to Mr B
• Funds are then progressively removed from her account on a monthly basis. Mr B is not accompanied by his wife when these transactions take place
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
More Information
Case Study 1
• Previous History of Cheque Fraud no charges laid as it was her son
• Instruction to the branch previously not to allow the son access to her funds
• Son abusive to Staff at their local branch, police called on several occasions
• Security required for Branch staff for 2 months
• Escalated to the Advocate Office in Queensland POA suspended pending investigation
Case Study 2
• My Mother suffering Dementia
• Administration order taken out
• Funds used to buy an Apartment for my father and disabled brother in a retirement village close to my mother
• Funds removed are for living expenses for my mother
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
Alzheimer's Stats:
• Based on current Alzheimer Australia Statistics the total population suffering from Dementia represents almost a Quarter of customers across the industry over 65
Alzheimer's Stats:
• 65 to 75 year olds with Dementia 10%
• 76 plus with Dementia 30%
This equates to:$42,000,000,000 Deposits
$ 8,000,000,000 Lending
National Conference & Exhibition 2014
Vulnerable Customers (Financial Abuse / Cognitive Impairments)
Thank you for your time today
Questions
Thank you.
NATIONAL CONFERENCE & EXHIBITION 2014
Platinum Sponsor
Silver Sponsor Bronze SponsorRisk Manager of the Year
Award Sponsor
Conference and Exhibition Partners