Congress Moves to Protect Seniors from Investment Fraud

Understanding the Proposed Financial Exploitation Prevention Act (H.R. 2478) and What It Means for Investors, Families, Financial Professionals, Broker-Dealers, RIAs, and Compliance Officers

Financial exploitation of older Americans has become one of the most serious investor-protection problems in the United States. Criminals increasingly target retirement accounts, brokerage accounts, mutual fund holdings, bank accounts, annuities, trust assets, and other accumulated savings using fraud, coercion, social engineering, impersonation, artificial intelligence, romance scams, cryptocurrency schemes, and abuse of positions of trust.

The proposed Financial Exploitation Prevention Act of 2025, H.R. 2478, is Congress’s latest effort to give financial institutions additional tools to intervene before suspicious redemptions and transfers become irreversible. As of the date of this article, H.R. 2478 remains proposed legislation. It has been introduced, reported favorably by the House Financial Services Committee, and placed on the House Union Calendar, but it has not become law. [1]

The bill would amend the Investment Company Act of 1940 to permit registered open-end investment companies and transfer agents to delay payment on certain redemptions when they reasonably believe that the redemption involves financial exploitation of a specified adult. The bill is narrower than many popular summaries suggest: it focuses on redemptions of securities issued by open-end investment companies, such as mutual funds, serviced through transfer agents, and is designed to complement, not replace, existing FINRA, state, and federal protections. [2]

For investors and families, the lesson is practical. Do not wait until money has vanished. Suspicious liquidation requests, sudden wire transfers, cryptocurrency transactions, new online relationships, caregiver pressure, changes in powers of attorney, or abrupt deviations from long-established investment patterns should be investigated immediately. For broker-dealers, RIAs, mutual fund companies, transfer agents, supervisors, and compliance personnel, H.R. 2478 is another indication that regulators and Congress expect earlier detection, better documentation, stronger escalation procedures, and effective training.

This article explains what H.R. 2478 would do, why Congress introduced it, how it fits within existing law, and what investors, families, financial professionals, and financial institutions should do now to prevent elder investment fraud and preserve legal rights when fraud is suspected.

I. America’s Growing Crisis of Elder Financial Exploitation

For millions of Americans, retirement represents the culmination of decades of work, saving, investing, and financial discipline. Those assets are supposed to provide independence, medical security, family stability, and dignity. Increasingly, however, older investors are being targeted precisely because they have accumulated assets and can authorize transactions quickly.

The FBI’s 2024 Internet Crime Report illustrates the scale of the problem. IC3 reported 859,532 complaints and $16.6 billion in losses in 2024, a 33 percent increase in reported losses from 2023. Individuals over age 60 submitted 147,127 complaints and reported $4.8 billion in losses, the highest loss total of any age group. [3]

Investment fraud was the largest reported loss category in the FBI’s 2024 data, accounting for more than $6.57 billion in reported losses. The report also identified cryptocurrency as a major descriptor, associated with more than $9.32 billion in reported losses across relevant complaint categories. [4] Cyber-enabled fraud accounted for approximately 83 percent of all reported IC3 losses in 2024. [5]

These figures almost certainly understate the actual magnitude of the problem. Many victims never report fraud because they are embarrassed, fear loss of independence, do not know where to report, or believe recovery is impossible. The CFPB has likewise reported that financial institutions filed more than 180,000 suspicious activity reports involving elder financial exploitation between 2013 and 2017, involving more than $6 billion. [6]

Congress has cited estimates that elder financial exploitation costs seniors more than $28 billion annually. [7] Whether measured by FBI complaints, CFPB suspicious activity reports, state regulatory data, or private research, the trend is unmistakable: older adults are losing life savings to increasingly sophisticated schemes.

Key Takeaway

Elder financial exploitation is not limited to isolated scams. It is a national investor-protection issue involving organized criminal networks, online fraud, cryptocurrency schemes, misuse of authority, and, in some cases, misconduct or supervisory failures within the financial services industry.

II. Why Congress Introduced H.R. 2478

H.R. 2478 did not arise in a vacuum. It is part of a broader legislative and regulatory progression that began with state elder-protection statutes, continued through FINRA’s trusted-contact and temporary-hold rules, and expanded through federal efforts to encourage reporting of suspected exploitation.

The Senior Safe Act, enacted as part of the Economic Growth, Regulatory Relief, and Consumer Protection Act, created immunity from liability for certain trained financial institution personnel who, in good faith and with reasonable care, disclose suspected exploitation of a senior citizen to a regulatory or law-enforcement agency. [8] The Senior Safe Act addressed reporting; it did not create a broad redemption-delay framework for mutual fund redemptions processed through transfer agents.

FINRA then adopted important rules applicable to broker-dealers. FINRA Rule 4512 requires member firms to make reasonable efforts to obtain the name and contact information of a trusted contact person for non-institutional accounts. [9] FINRA Rule 2165 permits member firms, in defined circumstances, to place temporary holds on disbursements or transactions involving accounts of specified adults when the firm reasonably believes financial exploitation has occurred, is occurring, has been attempted, or will be attempted. [10]

State securities regulators also acted. NASAA’s Model Act to Protect Vulnerable Adults from Financial Exploitation, adopted in 2016, encourages reporting to state securities regulators and adult protective services, authorizes limited third-party disclosures, permits delayed disbursements in appropriate circumstances, and provides immunity for good-faith compliance. [11] Many jurisdictions, including California, have enacted legislation or regulations based on or related to the NASAA model.

H.R. 2478 is the next step in that progression. The House Financial Services Committee described the bill as authorizing registered open-end investment companies and their transfer agents to delay redemptions when they reasonably believe financial exploitation is occurring or has been attempted. [12] In short, the legislation seeks to fill a practical gap in the protection of investors who hold mutual fund shares directly at the fund level or through transfer-agent relationships rather than in traditional brokerage accounts.

Legislative History

Representative Ann Wagner introduced H.R. 2478 on March 27, 2025. The bill was referred to the House Committee on Financial Services. The Committee reported the bill favorably, with an amendment, and recommended that it pass. [13] As of the date of this article, Congress.gov reflects that the bill was placed on the House Union Calendar on November 4, 2025, and has not become law. [1]

The bill has a prior legislative history. In the 118th Congress, Representative Wagner introduced H.R. 500, an earlier version of the Financial Exploitation Prevention Act. That bill passed the House under suspension of the rules by a vote of 419-0, was received in the Senate, and was referred to the Senate Committee on Banking, Housing, and Urban Affairs, but no further action occurred before the end of the 118th Congress. [14]

During the 119th Congress, the House Financial Services Committee considered H.R. 2478 in open session on September 16, 2025, adopted an amendment in the nature of a substitute by voice vote, and ordered the bill reported favorably by a recorded vote of 50-0. [15] That unanimous committee vote is significant. Protecting older investors from financial exploitation has generated bipartisan support because the problem is not ideological. It affects retirees, families, and financial institutions in every state.

III. What H.R. 2478 Would Do

H.R. 2478 is narrower, more technical, and more targeted than many readers may assume. It would amend Section 22 of the Investment Company Act of 1940 to address delayed payment or satisfaction upon redemption of certain securities in cases involving suspected exploitation of specified adults. The bill applies to registered open-end investment companies and certain transfer agents that elect to comply with the statute’s procedures. [2]

The core concept is straightforward. If an open-end investment company or transfer agent reasonably believes that a redemption involves financial exploitation of a specified adult, the company may delay redemption payment. The bill defines the protected population to include individuals age 65 or older and adults age 18 or older who are unable to protect their own interests because of a mental or physical impairment. [2]

The bill contemplates an initial delay of up to 15 days. If the company determines that exploitation has occurred, the delay may be extended for an additional 10 days. A state regulator, administrative agency, or court may extend the period further. Amounts subject to the delayed redemption must be held in a demand deposit account, and the bill establishes notification requirements

The bill also requires registered open-end investment companies and transfer agents that elect to use these procedures to notify the SEC. In addition, the SEC must report recommendations to Congress regarding regulatory or legislative changes needed to address financial exploitation of specified adults, after consulting with agencies and organizations including the CFTC, CFPB, FINRA, NASAA, the Federal Reserve, the OCC, and the FDIC. [16]

The bill does not authorize financial institutions to second-guess investment decisions simply because a customer is old, conservative, aggressive, or making an investment decision the firm considers unwise. The relevant trigger is reasonable belief of financial exploitation. That distinction is essential. Older adults do not lose autonomy because they age. Protective intervention must be based on objective evidence of fraud, coercion, deception, undue influence, or inability to protect one’s own interests.

What H.R. 2478 Is – and Is Not

H.R. 2478 is proposed federal legislation. It is not yet law.

It focuses on redemptions of certain open-end investment company securities serviced by transfer agents.

It would permit limited redemption delays when financial exploitation is reasonably suspected.

It is not a general license for financial institutions to block transactions simply because they disagree with an investor’s judgment.

IV. FINRA Rules 4512 and 2165: The Existing Framework

H.R. 2478 should be understood against the backdrop of FINRA Rules 4512 and 2165. Those rules remain central to broker-dealer elder-protection practices.

Rule 4512 requires broker-dealers to make reasonable efforts to obtain the name and contact information of a trusted contact person for a customer’s account, subject to specified limitations.[9] A trusted contact does not become a co-owner, agent, trustee, or power of attorney. The trusted contact has no authority to trade, withdraw funds, or make investment decisions. The purpose is narrower: the brokerage firm may contact that person in limited circumstances to address possible financial exploitation, confirm contact information, health status, or the identity of a legal guardian, executor, trustee, or power-of-attorney holder. [17]

Rule 2165 permits a member firm to place a temporary hold on a disbursement or transaction in an account of a specified adult if the firm reasonably believes financial exploitation has occurred, is occurring, has been attempted, or will be attempted. The rule defines a specified adult as a natural person age 65 or older, or an adult age 18 or older whom the firm reasonably believes has a mental or physical impairment rendering the person unable to protect his or her own interests. [10]

Rule 2165 also imposes procedural safeguards. The firm must provide notification, unless the person to be notified is unavailable or suspected of involvement in the exploitation; it must immediately initiate an internal review; it must limit the hold period unless extended as permitted; it must maintain written supervisory procedures; and it must keep records supporting its decision. [18]

The SEC, FINRA, and NASAA have continued to encourage trusted contacts as a practical investor-protection device. In 2025, their updated Investor Bulletin explained that a trusted contact is similar to an emergency contact and does not receive authority to make decisions or execute transactions in the investor’s account. [19]

V. How Elder Investment Fraud Occurs

The common denominator in most elder financial exploitation cases is not lack of intelligence by the victim. Victims include physicians, attorneys, accountants, professors, business owners, engineers, executives, and sophisticated investors. The common denominator is manipulation. Modern fraudsters understand psychology, technology, and timing.

Many schemes begin slowly. The victim receives a call, text, email, social-media message, or online introduction. The communication appears legitimate or emotionally compelling. The fraudster builds trust over days, weeks, or months. Eventually, the victim is encouraged to transfer money, liquidate securities, purchase cryptocurrency, change beneficiaries, grant account access, or keep the matter secret.

Artificial intelligence has increased the risk. Fraudsters can now generate polished emails, realistic voice recordings, forged documents, synthetic images, and personalized messages based on publicly available information. What once looked like obvious spam may now appear to come from a legitimate financial institution, government agency, family member, or trusted advisor.

Cryptocurrency scams are particularly dangerous because transactions can move quickly and recovery can be difficult. The FBI’s 2024 report described cryptocurrency investment fraud, often referred to as pig butchering, as a confidence-based scam in which criminals build an online relationship before introducing a fraudulent cryptocurrency investment platform. In Operation Level Up, the FBI notified 4,323 potential victims of cryptocurrency investment fraud; 76 percent were unaware they were being scammed, and estimated savings exceeded $285 million. [20]

Romance scams operate similarly. The initial request is rarely for money. The fraudster first creates emotional reliance. Eventually, an emergency, investment opportunity, travel problem, medical crisis, or business issue arises. The victim liquidates investments, withdraws retirement funds, wires money, or buys cryptocurrency because the request appears to come from someone who cares about them.

Other cases involve exploitation by family members, caregivers, trustees, or agents under powers of attorney. These cases can be harder to detect because the wrongdoer may already have access to the investor’s finances or may appear to be helping. Misuse of powers of attorney, improper beneficiary changes, self-dealing transfers, unauthorized loans, and pressure to execute estate-planning documents can all constitute financial exploitation.

Finally, some cases involve misconduct within the financial services industry itself. Unsuitable recommendations, unauthorized trading, excessive trading, selling away, misrepresentations, illiquid private placements, Ponzi schemes, and failures to supervise registered representatives may all cause recoverable losses. Not every investment loss is actionable, but losses caused by violations of legal or regulatory duties should be investigated.

Ten Warning Signs of Elder Financial Exploitation

• Sudden liquidation of long-held investments.
• Repeated or unusually large wire-transfer requests.
• New interest in cryptocurrency without prior experience.
• A new friend, romantic contact, caregiver, or relative directing financial decisions.
• Requests for secrecy or instructions not to contact family members.
• Unexplained beneficiary, address, or account-access changes.
• Confusion about transactions supposedly authorized by the investor.
• Pressure to act immediately.
• Investment decisions inconsistent with decades of prior objectives.
• Fear, anxiety, or reluctance when asked routine financial questions.

VI. Practical Guidance for Investors and Families

Prevention remains the best protection. Families should discuss financial safeguards before a crisis occurs. That discussion should respect independence while recognizing that fraud can affect anyone.

Investors should designate trusted contacts on brokerage accounts where available, review monthly statements promptly, verify significant transfer requests independently, use strong account-security practices, and pause before making urgent decisions. Any request to keep a transaction secret from family, counsel, accountants, or trusted advisors should be treated as a serious warning sign.

Adult children and other family members should look for changes in behavior, not merely changes in account values. Sudden secrecy, new relationships involving money, anxiety when discussing finances, unexplained withdrawals, or abrupt changes in estate planning may warrant closer review. The goal is not to take control of a parent’s finances. The goal is to ensure that decisions are being made freely, knowingly, and without coercion or deception.

When suspicious activity is detected, time matters. Contact the financial institution immediately. Ask whether transfers can be delayed, whether a fraud department can review the transaction, and whether additional account controls are available. Preserve emails, texts, voicemails, account statements, confirmations, transfer instructions, and names of everyone involved. Do not delete messages out of embarrassment.

Why Early Intervention Changes Outcomes

The practical difference between early and late intervention can be decisive. A pending wire transfer may be stopped. A recent transfer may sometimes be recalled. A suspicious redemption may be delayed if the institution has legal authority and adequate procedures. A cryptocurrency transfer, by contrast, may become effectively unrecoverable once the assets move through multiple wallets controlled by criminals.

Early intervention also preserves choices. Families may be able to involve trusted contacts before a victim becomes isolated. Counsel may be able to send preservation demands before emails, telephone recordings, account notes, CRM entries, and surveillance materials are destroyed in the ordinary course. Financial institutions may be able to conduct an internal review while employees still remember the relevant conversations. Law enforcement may be able to trace funds before they are layered through additional accounts.

Delay has the opposite effect. Victims often wait because they are embarrassed, because they trust the person asking for money, or because they hope the situation can be resolved privately. In family exploitation cases, delay may result from understandable reluctance to accuse a relative or caregiver. In romance scams, victims may continue believing the relationship is genuine even after objective evidence suggests fraud. In investment schemes, victims may be told that withdrawals are delayed only because of administrative problems or taxes.

For investors and families, the most practical rule is simple: investigate first and apologize later. Asking questions is not disrespectful. A legitimate advisor, fiduciary, family member, caregiver, or investment sponsor should be able to explain the transaction, provide documents, and allow reasonable time for review. A person who insists on secrecy, urgency, or isolation is creating a red flag that should not be ignored.

Immediate Steps If Fraud Is Suspected

• Contact the financial institution immediately and ask for the fraud or compliance department.
• Request review or delay of pending transfers where legally available.
• Preserve all emails, texts, voicemails, account statements, wire instructions, and screenshots.
• Change passwords and enable multi-factor authentication if account access may be compromised.
• Report criminal conduct to law enforcement or the FBI’s IC3 portal where appropriate.
• Consult experienced securities counsel promptly before additional assets are transferred.

VII. Guidance for Broker-Dealers, RIAs, Mutual Fund Companies, Transfer Agents, and Compliance Departments

For financial institutions, H.R. 2478 should be viewed as more than proposed legislation. It reflects evolving expectations. Regulators, courts, arbitration panels, and customers increasingly expect firms to recognize patterns of exploitation, train personnel, escalate concerns, and document their decisions.

Broker-dealers should evaluate whether their Rule 4512 trusted-contact processes are effective in practice, not merely on paper. Firms should ask whether trusted contacts are obtained, updated, and used appropriately. They should also review whether Rule 2165 procedures identify who may place or extend a hold, when legal or compliance review is required, how notifications are documented, and how suspicious activity is escalated.

RIAs should consider comparable policies even where FINRA rules do not directly apply. Advisers owe fiduciary duties and often maintain long-standing relationships with clients. They may be well positioned to identify sudden changes in behavior, unusual instructions, or third-party influence. Investment adviser representatives should be trained to escalate concerns rather than informally resolving them in isolation.

Mutual fund companies and transfer agents should pay particular attention to H.R. 2478 because the bill is directed to open-end investment company redemptions and transfer-agent relationships. Firms that could elect to rely on the proposed procedures should begin considering how they would document reasonable belief, notify appropriate parties, hold redemption amounts, and coordinate with regulators if the bill is enacted.

Compliance departments should create multidisciplinary protocols involving legal, supervision, operations, fraud, technology, and client-facing personnel. A customer-service employee may see a change of address; operations may see a new ACH instruction; the advisor may see a liquidation request; compliance may see a suspicious pattern. The system must connect those observations before assets leave the institution.

Compliance Checklist for Financial Institutions

• Do written supervisory procedures address elder financial exploitation directly?
• Are trusted contacts obtained and updated consistently?
• Are employees trained on AI scams, romance scams, crypto fraud, caregiver exploitation, and powers of attorney?
• Does the firm have clear escalation procedures for suspicious disbursements and redemptions?
• Are temporary holds documented with objective facts and supervisory approval?
• Can the firm aggregate warnings across departments?
• Are incident files sufficient for review by regulators, courts, or FINRA arbitration panels?

VIII. Legal Remedies Available Today

Investors do not need to wait for H.R. 2478 to become law before seeking legal advice. Existing remedies may be available under federal securities laws, state securities statutes, FINRA arbitration rules, fiduciary-duty principles, negligence law, contract law, elder financial abuse statutes, and common-law fraud theories.

Many disputes involving broker-dealers and registered representatives are resolved in FINRA arbitration. Potential claims include unsuitable recommendations, unauthorized trading, excessive trading, misrepresentation, omission of material facts, breach of fiduciary duty, negligence, failure to supervise, selling away, and breach of contract. FINRA arbitration is a specialized forum, and effective representation requires knowledge of securities law, industry practices, supervision, discovery, damages, and expert testimony.

California investors may also have remedies under California elder abuse law. California Welfare and Institutions Code section 15610.30 defines financial abuse of an elder or dependent adult to include taking, secreting, appropriating, obtaining, or retaining property for wrongful use or with intent to defraud, assisting such conduct, or taking property by undue influence. [21] Depending on the facts, California elder-abuse remedies may materially affect strategy and recovery.

Claims may exist not only against the immediate wrongdoer but also against broker-dealers, RIAs, supervisors, trustees, attorneys-in-fact, caregivers, family members, promoters, or financial institutions whose misconduct, negligence, breach of fiduciary duty, or failure to supervise contributed to the loss. Identifying all potentially responsible parties is often critical.

Prompt legal action matters. Electronic records can be deleted, account notes overwritten, recordings purged, witnesses lost, cryptocurrency moved through wallets, and bank wires dispersed. Preservation letters, emergency communications with financial institutions, reports to law enforcement, and early factual investigation can materially affect the ability to recover funds or prove liability.

IX. Why Experienced Securities Counsel Matters

Elder financial exploitation cases often sit at the intersection of securities law, fiduciary duty, elder abuse, banking procedures, cybersecurity, arbitration, regulatory compliance, and family dynamics. A narrow approach can miss important claims. A lawyer who sees only a family dispute may overlook broker-dealer supervision. A lawyer who sees only an investment loss may overlook undue influence. A lawyer who sees only fraud by an outsider may overlook whether a financial institution ignored red flags.

Experienced securities counsel can analyze account records, identify suspicious transactions, preserve evidence, evaluate statutes of limitation, determine whether FINRA arbitration applies, assess supervisory failures, coordinate with forensic experts where needed, and pursue recovery from responsible parties. Counsel can also advise financial professionals, broker-dealers, RIAs, and compliance personnel on policies, internal investigations, remediation, and regulatory exposure.

Shustak Reynolds & Partners represents investors, financial professionals, broker-dealers, registered investment advisers, hedge funds, and businesses in FINRA arbitrations, securities litigation, SEC and FINRA investigations, broker transition disputes, investment fraud matters, fiduciary-duty claims, and complex commercial disputes. Erwin J. Shustak, George C. Miller, and Joseph C. Mellano handle securities litigation, FINRA arbitration, broker misconduct, regulatory investigations, and financial services disputes. Robert Boeche advises broker-dealers, RIAs, private funds, and financial industry participants on regulatory, compliance, and enforcement issues.

That breadth matters. Elder investment fraud can present both investor-recovery issues and industry-compliance issues. The same fact pattern may require urgent evidence preservation, FINRA arbitration analysis, SEC or FINRA regulatory assessment, review of supervisory procedures, and practical judgment concerning family, fiduciary, and reputational considerations.

Frequently Asked Questions

No. As of the date of this article, H.R. 2478 remains proposed legislation. It has been introduced, reported favorably by the House Financial Services Committee, and placed on the House Union Calendar, but it has not become law. [1]

Does H.R. 2478 apply to every brokerage transaction?

No. The bill focuses on redemptions of certain securities issued by registered open-end investment companies and serviced by transfer agents. Existing FINRA rules and state laws may apply in different circumstances.

Does naming a trusted contact give that person control over my account?

No. A trusted contact does not receive authority to trade, withdraw money, or make decisions. The designation allows the firm to contact that person in limited circumstances, such as suspected financial exploitation or difficulty reaching the customer. [19]

Can investors recover money lost to elder financial exploitation?

Sometimes. Recovery depends on the facts, the defendants, the available evidence, applicable limitations periods, and whether a responsible party violated a legal duty. Prompt investigation materially improves the ability to evaluate recovery options.

Conclusion

H.R. 2478 reflects a broader national recognition that elder financial exploitation is a serious, growing, and increasingly sophisticated threat. Whether the bill is enacted in its present form, modified, or delayed, its policy message is clear: financial institutions must be prepared to identify suspected exploitation before retirement assets disappear, and investors and families must act quickly when warning signs appear.

Financial exploitation is no longer limited to crude scams or obvious misconduct. It now includes AI-enabled impersonation, cryptocurrency fraud, romance scams, caregiver pressure, misuse of powers of attorney, unsuitable investment recommendations, unauthorized trading, Ponzi schemes, and failures of supervision. The legal response must be equally sophisticated.

If you or a family member has sustained losses through suspected elder investment fraud, broker misconduct, unauthorized trading, unsuitable investments, financial exploitation, misuse of a power of attorney, or suspicious account activity, contact Shustak Reynolds & Partners promptly. Early legal intervention can help preserve evidence, identify responsible parties, evaluate claims, and protect remaining assets.

For broker-dealers, RIAs, mutual fund companies, transfer agents, supervisors, and compliance officers, H.R. 2478 is an opportunity to review policies before the next crisis. Effective procedures, training, documentation, and escalation are not merely regulatory obligations; they are essential tools for protecting clients and reducing legal and reputational risk.

This article is for informational purposes only and does not constitute legal advice. Every matter depends on its own facts, and readers should consult qualified counsel regarding their specific circumstances.

Shustak Reynolds & Partners, P.C. focuses its practice on securities and financial services law and complex business disputes.
We represent many investment advisors, financial professionals, broker-dealers, registered representatives, investors and businesses.
Attorney Erwin J. Shustak can be reached in the firm’s San Diego office at (619) 696-9500.

1. Congress.gov, H.R. 2478 – Financial Exploitation Prevention Act of 2025, 119th Cong. (2025-2026), sponsor, latest action, and legislative status, https://www.congress.gov/bill/119th-congress/house-bill/2478.

2. Congress.gov, H.R. 2478 summary, describing the bill as establishing procedures for delaying redemption of certain securities when an investment company or agent believes an older individual or impaired adult has been financially exploited, https://www.congress.gov/bill/119th-congress/house-bill/2478.

3. Federal Bureau of Investigation, Internet Crime Complaint Center, 2024 IC3 Annual Report, pp. 3, 7-8, reporting 859,532 complaints, $16.6 billion in losses, and $4.8 billion in losses reported by individuals age 60 and older, [PDF DOWNLOAD] https://www.ic3.gov/AnnualReport/Reports/2024_IC3Report.pdf.

4. FBI IC3, 2024 Annual Report, pp. 9-10, reporting investment-fraud losses of $6,570,639,864 and cryptocurrency-nexus losses of $9,322,335,911.

5. FBI IC3, 2024 Annual Report, p. 11, reporting that cyber-enabled fraud accounted for almost 83 percent of IC3-reported losses in 2024.

6. Consumer Financial Protection Bureau, Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends (Feb. 27, 2019), reporting more than 180,000 EFE SARs involving more than $6 billion from 2013-2017, https://www.consumerfinance.gov/data-research/research-reports/suspicious-activity-reports-elder-financial-exploitation-issues-and-trends/.

7. H. Rept. 119-361, Financial Exploitation Prevention Act of 2025, Background and Need for Legislation, citing AARP Public Policy Institute estimates that financial exploitation costs seniors more than $28 billion annually, https://www.congress.gov/committee-report/119th-congress/house-report/361/1.

8. Congress.gov, H.R. 3758 – Senior Safe Act of 2017, summary describing immunity for trained financial institution personnel who disclose suspected senior exploitation in good faith and with reasonable care, https://www.congress.gov/bill/115th-congress/house-bill/3758.

9. FINRA Rule 4512(a)(1)(F) and Supplementary Material .06, trusted contact person requirements, https://www.finra.org/rules-guidance/rulebooks/finra-rules/4512.

10. FINRA Rule 2165, Financial Exploitation of Specified Adults, definitions and temporary hold provisions, https://www.finra.org/rules-guidance/rulebooks/finra-rules/2165.

11. NASAA, Model Act to Protect Vulnerable Adults from Financial Exploitation, overview and key provisions, https://www.nasaa.org/industry-resources/senior-issues/model-act-to-protect-vulnerable-adults-from-financial-exploitation/.

12. H. Rept. 119-361, Purpose and Summary, describing H.R. 2478 as allowing registered open-end investment companies and transfer agents to implement safeguards delaying redemptions where financial exploitation is reasonably suspected.

13. H. Rept. 119-361, Committee report language noting introduction of H.R. 2478 by Representative Ann Wagner on March 27, 2025, referral to House Financial Services, and favorable report with amendment.

14. H. Rept. 119-361, Committee Consideration, 118th Congress history of H.R. 500 and House passage by vote of 419 yeas and 0 nays.

15. H. Rept. 119-361, Committee Votes, noting that on September 16, 2025, the Committee ordered H.R. 2478, as amended, to be reported favorably by recorded vote of 50 yeas and 0 nays.

16. H.R. 2478, as reported, Section 2(b), requiring the SEC to report recommendations to Congress after consulting with the CFTC, CFPB, FINRA, NASAA, Federal Reserve, OCC, and FDIC.

17. SEC Office of Investor Education and Assistance, FINRA, and NASAA, Why You Should Consider Adding a Trusted Contact to Your Account – Updated Investor Bulletin (Aug. 25, 2025), https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/investor-bulletins-trusted-contact.

18. FINRA Regulatory Notice 17-11, SEC Approves Rules Relating to Financial Exploitation of Seniors (Mar. 30, 2017), discussing Rules 2165 and 4512, temporary holds, trusted contacts, notification, recordkeeping, supervision, and training, https://www.finra.org/rules-guidance/notices/17-11.

19. SEC/FINRA/NASAA Investor Bulletin on Trusted Contacts, explaining that naming a trusted contact does not give the person authority to execute trades, make decisions, or act as power of attorney.

20. FBI IC3, 2024 Annual Report, Operation Level Up discussion, reporting notifications to 4,323 cryptocurrency investment-fraud victims, 76 percent of whom were unaware they were being scammed, and estimated savings exceeding $285 million.

21. California Welfare and Institutions Code section 15610.30, defining financial abuse of an elder or dependent adult, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=WIC&sectionNum=15610.30.