• Obtain contact information for persons who are trusted by the senior client and have the senior client agree that you may contact them if you have concerns.
• Provide training to advisors and staff in your firm to identify red flags for diminished capacity and elder financial abuse and develop policies to escalate the matter when red flags are identified.
• Require periodic, annual, updated training to ensure a high level of awareness within your firm.
• Review each of the SEC’s requests, determine the appropriate responses for your firm, document those decisions in your policies, and review and update those practices periodically.

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