Elder financial exploitation hold and report

How do we act when staff suspect elder financial exploitation, with the hold, the trusted contact outreach and the reports done under the rules?

Give the frontline a way to raise it and the bank a process to act. A teller or banker flags the concern from the case they are in; Callvu captures the facts, classifies the risk, places the temporary hold the bank's policy and state law allow, routes the fraud team's decision in the Decision Desk, reaches the trusted contact where one is on file, files the adult protective services and SAR reports on their clocks, and records every step with its date for the examiner and for the customer.

In scopeComplex: multi-party handoffsCallvu moves: classify, chase and verify, decide

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Last updated November 6, 2026.

The problem today

The teller sees it, tells a supervisor, and the withdrawal goes through because nobody was sure they could stop it.

Today, without Callvu

An older customer comes in with a new 'friend' and asks to wire their savings. The teller is uneasy. The supervisor is not sure a hold is allowed, the customer insists, and the wire goes. A week later the family calls. The report to adult protective services is written from memory.

Most states now allow a bank to delay a disbursement when it reasonably believes financial exploitation of an eligible adult, for a defined period, with notice to the account parties and to the state agency, and give immunity for a good-faith report. The Senior Safe Act protects trained staff who report to the right agency. The bank's policy decides who may place the hold and how long, and a trusted contact designation, where the bank offers one, gives someone to call.

The decisions are time-bound and the protections depend on following the steps in order. A concern raised in a hallway is not a process.

How it runs

From the requestto the system of record.

A frontline employee flags a concern from the transaction or interaction they are handling, or monitoring raises an alert on an account flagged as an eligible adult's. Callvu opens the case with the facts and the time.

Front-line staff: Raises the concern with the facts they observed, from the case they are in; does not decide the hold.
Fraud team: Decides the hold, the outreach and the reports in the Decision Desk, within the clocks.
Compliance: Files or approves the regulatory reports and sees the pattern.
Callvu: Captures, classifies, applies the hold the policy allows, routes decisions, reaches the trusted contact, files reports on their clocks and records.

Capture and classify
The employee records what they saw on a structured screen: the transaction, the people present, the indicators (a new person controlling the conversation, unusual urgency, a change in pattern, confusion, a recent contact change). Callvu classifies the risk and checks the account for the eligible-adult flag, a trusted contact, a power of attorney and recent changes.
Decide the hold
The case goes to the fraud team in the Decision Desk with the facts and the policy's options under the state's statute: delay the disbursement for the allowed period, allow it, or allow with a safeguard (a call to the trusted contact first, a smaller amount). A delay is recorded with its start, its statutory maximum and the notice obligations it triggers.
Chase and verify
The trusted contact, where one is on file, is reached through the channel the designation allows, and the conversation is recorded on the case. The customer is contacted separately, away from the person of concern where possible. Documents such as a power of attorney presented in the interaction are checked as in the POA process.
Report on the clocks
Where the state requires or allows it, the report to adult protective services (and to the state securities or banking regulator where the statute names them) is filed within the statute's period with the facts from the case. Where the activity meets the threshold, a SAR with the elder financial exploitation indicator is filed within 30 days of detection. Each filing is recorded.
Write back
The hold, its expiry, the outreach, the decisions and the reports are written to the core and the fraud case, and the account carries the flag and the trusted contact for next time. The hold is released or extended by the fraud team before the statutory period ends.

Where it ends: The disbursement was delayed or allowed by a decision inside the statute, the trusted contact and the customer were reached, the reports were filed on their clocks, and every step is recorded with its date. The Decision Trace shows the classification and the decision; the Audit Trace shows each contact and filing.

Runtime enforcement

What is enforcedwhile the work runs.

The regulations preloaded in Callvu Studio and the bank's own policies, applied as steps that run, not lines in a binder. A step that breaks a rule does not run, so a completed run was compliant.

Regulations

State reporting laws and disbursement delay statutes (for example statutes modeled on the NASAA Model Act and state elder abuse reporting laws): Many states permit a financial institution that reasonably believes financial exploitation of an eligible adult (typically 65 and older, or a vulnerable adult) to delay a disbursement for a defined period (commonly 15 business days, extendable), require notice to the parties authorized on the account and to the state agency, and provide immunity for good-faith actions. Many also require or permit a report to adult protective services within a set period. The bank's policy carries the rules for each state it operates in.
Senior Safe Act (12 USC 3423): A financial institution and its trained employees are immune from liability for reporting suspected exploitation of a senior citizen to a covered agency, in good faith and with reasonable care, if the institution has provided the training the Act describes. The case records that the reporting employee was trained.
FINRA 2165 style trusted contact rules where applicable: FINRA Rule 2165 and Rule 4512 (for broker-dealers) allow a temporary hold on disbursements where exploitation is suspected and require asking for a trusted contact; banks with brokerage affiliates apply them there, and many banks adopt the same trusted contact and temporary hold practice for deposit accounts under state law and their own policy.
BSA suspicious activity reporting (31 CFR 1020.320) and FinCEN's elder financial exploitation advisories: Suspected exploitation meeting the threshold is reported on a SAR within 30 days of detection, with the elder financial exploitation indicator and the narrative details FinCEN's advisories request.

Company policies

The frontline raises; the fraud team decides. The hold options and their periods are the state's statute as carried in the bank's policy.
A delay is recorded with its start and statutory maximum, and the notices it triggers are sent from the case.
The trusted contact, where designated, is reached before the hold expires.
Reports to adult protective services and the SAR are filed from the case within their periods.
The fraud case is the system of record; the core carries the hold and the flag.

Controls

Structured capture of indicators by the frontline.
Account checks for eligible-adult flag, trusted contact, POA and recent changes.
Decision Desk control of the hold with the statute's options.
Hold expiry tracked against the statutory period.
Trusted contact and customer outreach recorded.
Report filings on their clocks, with the trained-employee record.
Flag and trusted contact written to the account for the future.

Clocks and deadlines

Disbursement delay: The state's period (commonly 15 business days, extendable under the statute), tracked from the hold's start.
Notice of delay: To the parties authorized on the account and the state agency within the statute's period after the delay.
Adult protective services report: Within the state's period where required or elected.
SAR: Within 30 calendar days of detection where the threshold is met.

Documents and checks

The frontline's structured report with the indicators and the time
The account checks (flag, trusted contact, POA, recent changes)
The fraud team's decision on the hold with its period
The notices sent and the outreach records
The APS report and the SAR with their filing dates
The hold release or extension record

In the Decision Trace

The classification and the indicators behind it.
The hold decision, the statute relied on and the period.
The outreach outcomes.
The reports filed and when.

In the Audit Trace

The flag raised, by whom and when.
The Decision Desk steps with the person and the time.
Each contact with the trusted contact and the customer.
The hold's start, notices, filings and release.

The handoff

Between the front doorand the back office.

The front door

The teller line, the branch desk, the contact center, or monitoring. The employee raises the concern from the case in front of them, in a minute.

The back office

The fraud team decides within the statute, compliance files from the record. No one has to be sure whether a hold is allowed; the policy in the process is.

The Decision Desk

The hold decision goes to the fraud team in the Decision Desk with the facts, the account checks and only the statute's options: delay, allow, or allow with a safeguard.
The release or extension goes back to the fraud team before the period ends.

Proof

In scope.Proof at scale, not one process at a time.

The kind of process Callvu runs in production for customers in this industry. Ask for a reference on this exact process. The results below are the industry's published proof; each claim code links to its record on agents.callvu.com.

More than 1,000 processes are live across Callvu customers.

Across Callvu customers

Banca Transilvania automated more than 100 workflows with Callvu.

BNK-04

Bank Leumi digitized all loan application and servicing workflows within six months, and dozens more processes since.

BNK-01

Questions

What buyers ask next,answered plainly.

Can a teller place the hold?

The teller raises the concern with the facts. The fraud team decides the hold in the Decision Desk with the options the state's statute allows, and the hold is recorded with its period.

How long can the disbursement be delayed?

For the period the state's statute allows, commonly 15 business days with an extension, tracked on the case from the start of the hold, with the required notices sent.

Who is contacted?

The trusted contact on file, through the channel the designation allows, and the customer separately. Both contacts are recorded.

What protects the employee who reports?

The Senior Safe Act's immunity for trained employees reporting in good faith, and the state's good-faith provisions. The case records the training and the report.

Related processes

Power of attorney registration Wire recall and fraud claims Customer complaint intake and resolution Try it in the sandbox All banking and credit unions processes

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