Eligible Adult

Hattie Grimshawe, 81, has an account at Verrowby Securities and named her stepson as her trusted contact person when she opened it. A supervisor at the firm develops a reasonable belief that a caller who has been directing activity in the account is financially exploiting her. Under the NASAA Model Act to Protect Vulnerable Adults from Financial Exploitation, the firm:

1. A.may notify the Administrator but must first obtain Grimshawe written consent, since the account is hersNo client consent is required. The notification duty exists precisely because the client may be under undue influence.
2. B.must notify only Adult Protective Services, because the state securities Administrator has no role in elder exploitation mattersThe model act names the securities Administrator alongside Adult Protective Services as a required recipient.
3. C.must promptly notify the Administrator and Adult Protective Services, and may also notify the trusted contact personCorrect. Regulator and Adult Protective Services notification is mandatory; trusted contact notification is permissive.
4. D.must notify the trusted contact person first, and may notify the Administrator only if the stepson does not resolve the matterThis reverses the structure. Trusted contact notification is optional and does not gate the required notifications.

Why: The model act separates a mandatory step from a permissive one. A qualified individual who reasonably believes that financial exploitation of an eligible adult has occurred, has been attempted, or is being attempted must promptly notify both the state securities Administrator and Adult Protective Services. Notifying a trusted contact person is permitted rather than required, and no notification may be made to a person the firm suspects of the exploitation.

On Monday, June 1, 2026, Wraycombe Securities reasonably believes that a requested 90,000 dollar wire out of the account of Estella Fenwick-Doyle, age 84, will result in her financial exploitation, and it places a delay on the disbursement that same day. It opens an internal review. Under the NASAA Model Act to Protect Vulnerable Adults from Financial Exploitation, which statement about the delay is correct?

1. A.Notification must go out within fifteen business days, and the delay may continue indefinitely until the internal review concludesNotification runs on a two business day clock and the delay has a definite statutory expiry.
2. B.Notification must go out no more than two business days after the delay is placed, and the delay expires no later than fifteen business days after it was placed, extendable to twenty-five business days if the internal review supports the beliefCorrect. Those are the notification deadline, the base expiry and the extended outer limit under the model act.
3. C.The delay expires after two business days unless a court extends it, and no notification to the Administrator is requiredTwo business days is the notification deadline, not the life of the delay, and Administrator notification is required.
4. D.No delay is permitted at all unless a court order is obtained first, because the account owner controls her own fundsThe model act authorises the firm to place the delay itself, subject to notification and expiry requirements.

Why: The firm must provide notification of the delay and the reason for it, no more than two business days after the delay is first placed, to all parties authorized to transact business on the account other than any party suspected of the exploitation, and it must notify the Administrator and Adult Protective Services. The delay expires no later than fifteen business days after it was first placed. If the internal review supports the belief, the delay may be extended to no more than twenty-five business days after it was first placed, and the Administrator or a court may terminate or further extend it.