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Seniors in the Coming Year | Carlton Fields


Continued FINRA Focus
If regulatory developments in 2020 are any indication, FINRA’s efforts to protect senior customers from financial exploitation and vulnerability will continue in 2021 and beyond.
As part of its retrospective review of its rules and administrative process designed to help protect senior customers, in late fall 2020 FINRA proposed amendments to Rule 2165 and revised its Sanction Guidelines in ways designed to further protect senior customers.
FINRA Rule 2165
When a firm reasonably believes that financial exploitation of a “specified adult” has occurred, is occurring, has been attempted, or will be attempted, Rule 2165 permits a firm to place a temporary hold of up to 25 business days on disbursements of funds or securities from the account of a specified adult customer. In addition to seniors, “specified adults” includes other adults who have mental or physical impairments that may render them unable to protect their interests. ....

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