CEJC A*Team
Addressing Systemic Barriers to Elder Justice
Established through a 2021 grant from the U.S. Department of Justice Office for Victims of Crime, CEJC’s A*Team was a specially selected group of policy experts convened to examine the systemic issues that plague elder abuse MDTs’ work. The A*Team created the space for elder abuse multidisciplinary teams (MDT) to share systemic issues that prevent case resolution, such as restricted access to information, a lack of capacity evaluations, or other impediments.
This solution-oriented body was composed of thought leaders with expertise in elder abuse law, prosecution, investigations, and victim services. The A*Team reviewed and researched obstacles encountered by local elder abuse multidisciplinary teams and recommended policy and programmatic changes to improve the system statewide. The A*Team project was funded by a three-year OVC Enhanced Multidisciplinary Team grant.
The work of CEJC’s A*Team continues to inform many of CEJC’s ongoing priorities.
Members of the A*Team were selected for their experience and understanding of the laws and practices involved in the investigation, prosecution and prevention of elder abuse and remain trusted advisors in CEJC’s ongoing work. Members included:
Seeking Protections for the Most Vulnerable Among Us
The third year of the A*Team project shifted the team’s focus to a new and little-understood issue facing many of the most vulnerable adults. “Benefits trafficking” occurs when an unlicensed room and board operator takes over a vulnerable resident’s income and benefits, either through undue influence or an illegal rental contract requiring the renter to sign over benefits to the operator. Operators may be abusive or withhold food or assistance if residents object to the loss of benefits or complain about their living conditions.
First coming to the team’s attention through members of Fresno County’s elder abuse multidisciplinary team, the A*Team has learned these practices by unlicensed room and board homes are common across the state. Victims of these crimes are often recent hospital discharges who are unable to afford licensed residential care. California does not recognize “benefits trafficking” as a crime, instead relying on the universe of regulatory agencies to act independently when specific violations become known. The result is an unchecked and lucrative system of unscrupulous property owners renting rooms to those least able to defend themselves.
The A*Team met with MDTs, county officials, the Attorney General’s Office, California Community Care Licensing, and an author of Georgia’s effective benefits trafficking law, to study the roots of this problem and possible solutions. Earlier this spring the group learned about an innovative elder shelter/support program run by WEAVE in Sacramento, a domestic violence program that has expanded its reach to serve abuse survivors who are male, LGBTQ, and the elderly.
CEJC continues work to elevate this issue to policy makers and other advocates.
CEJC’s A*Team Focus on Systemic Issues: Building understanding; Exploring Solutions
The A*Team’s focus on issues that impact the work of local multidisciplinary teams (MDTs) included difficulty accessing bank records when investigating elder financial exploitation, the lack of placement options when an older adult needs to be removed from a dangerous situation, too few professionals to conduct capacity assessments, lack of access to civil attorneys, and uncertainty around reports of abuse in unlicensed care homes.
Delving into the banking issues, the A*Team met with bankers and state and federal regulators in an effort to understand the nuances of compliance with state versus federal requirements and to explore possible solutions, including new technologies that could streamline the confidential exchange of information. Members met with representatives of the state banking regulators, federal Consumer Financial Protection Bureau, the Securities Industry Financial Markets Association (SIFMA), and the operator of HelpVulTM, a banking information exchange platform. Joining with the County Welfare Directors Association, CEJC co-sponsored AB 871 in 2025 to clarify and strengthen mandated reporting responsibilities of bank personnel.
Along with outreach to stakeholders and highlighting innovations, the A*Team has developed guidance for MDTs working with banks and an MDT resource page providing updated training and guidance materials for multidisciplinary teams.
The A*Team project was funded through a three-year grant from the USDOJ Office for Victims of Crime.
Addressing Systemic Barriers to Elder Justice
CEJC’s A*Team Tackles MDT/Bank Interactions During Investigations
The Problem
Multidisciplinary teams report one of the most common obstacles to financial exploitation investigations is the lack of bank compliance with requests for customer records that are needed as evidence. The A*Team worked to identify solutions to address the banking industry’s reluctance to comply with investigator’s record requests. Internal bank protocol and regulatory restrictions make it difficult for them to stop transactions when an account holder insists the payment is legitimate or to communicate with the bank receiving the funds. Understanding the factors contributing to these hurdles were key to finding a solution.
The Legal Framework
Banks are authorized to comply with investigators’ requests by multiple privacy exemptions in state and federal law and under different regulatory authorities, which appear to confuse, rather than clarify, the responsibility.
Additionally, banks are authorized to hold certain suspicious transactions for up to 15 days under Welfare and Institutions Code 15630.2 (j)(1). The law allows a court order to extend the bank hold at investigators’ request. Welfare and Institutions Code 15630.2 (j)(4) exempts a mandated reporter of suspected financial abuse from civil liability for delayed transactions held in good faith.
Many banks cite liability concerns when declining investigators’ requests, despite the state and federal statutory exemptions. Banks also require reports of suspicious or known fraudulent activity to be approved by management or legal counsel before reports can be filed, creating a direct conflict with the individual employee’s mandated reporting duty and without regard for their own liability for failure to report.
Partnering with the County Welfare Directors Association, CEJC co-sponsored AB 871 in 2025, to clarify and strengthen mandated reporting responsibilities of bank personnel.
A*Team Recommendations
1. Possible solutions to address these challenges include:
To learn more about the A*Team or to request ongoing updates, email [email protected]
This solution-oriented body was composed of thought leaders with expertise in elder abuse law, prosecution, investigations, and victim services. The A*Team reviewed and researched obstacles encountered by local elder abuse multidisciplinary teams and recommended policy and programmatic changes to improve the system statewide. The A*Team project was funded by a three-year OVC Enhanced Multidisciplinary Team grant.
The work of CEJC’s A*Team continues to inform many of CEJC’s ongoing priorities.
Members of the A*Team were selected for their experience and understanding of the laws and practices involved in the investigation, prosecution and prevention of elder abuse and remain trusted advisors in CEJC’s ongoing work. Members included:
- Melissa Brown, JD, Elder Law Clinic Director, McGeorge School of Law
- Debbie Deem, FBI Victim Advocate, Retired, and FAST Team Coordinator
- Paul Greenwood, Elder Abuse Unit Prosecutor, San Diego District Attorney’s Office (Retired)
- Andrea Higgens, Elder Abuse Investigator, San Mateo District Attorney’s Office
- Angela Rosato, Coordinator, Riverside County Elder Abuse Forensic Center
Seeking Protections for the Most Vulnerable Among Us
The third year of the A*Team project shifted the team’s focus to a new and little-understood issue facing many of the most vulnerable adults. “Benefits trafficking” occurs when an unlicensed room and board operator takes over a vulnerable resident’s income and benefits, either through undue influence or an illegal rental contract requiring the renter to sign over benefits to the operator. Operators may be abusive or withhold food or assistance if residents object to the loss of benefits or complain about their living conditions.
First coming to the team’s attention through members of Fresno County’s elder abuse multidisciplinary team, the A*Team has learned these practices by unlicensed room and board homes are common across the state. Victims of these crimes are often recent hospital discharges who are unable to afford licensed residential care. California does not recognize “benefits trafficking” as a crime, instead relying on the universe of regulatory agencies to act independently when specific violations become known. The result is an unchecked and lucrative system of unscrupulous property owners renting rooms to those least able to defend themselves.
The A*Team met with MDTs, county officials, the Attorney General’s Office, California Community Care Licensing, and an author of Georgia’s effective benefits trafficking law, to study the roots of this problem and possible solutions. Earlier this spring the group learned about an innovative elder shelter/support program run by WEAVE in Sacramento, a domestic violence program that has expanded its reach to serve abuse survivors who are male, LGBTQ, and the elderly.
CEJC continues work to elevate this issue to policy makers and other advocates.
CEJC’s A*Team Focus on Systemic Issues: Building understanding; Exploring Solutions
The A*Team’s focus on issues that impact the work of local multidisciplinary teams (MDTs) included difficulty accessing bank records when investigating elder financial exploitation, the lack of placement options when an older adult needs to be removed from a dangerous situation, too few professionals to conduct capacity assessments, lack of access to civil attorneys, and uncertainty around reports of abuse in unlicensed care homes.
Delving into the banking issues, the A*Team met with bankers and state and federal regulators in an effort to understand the nuances of compliance with state versus federal requirements and to explore possible solutions, including new technologies that could streamline the confidential exchange of information. Members met with representatives of the state banking regulators, federal Consumer Financial Protection Bureau, the Securities Industry Financial Markets Association (SIFMA), and the operator of HelpVulTM, a banking information exchange platform. Joining with the County Welfare Directors Association, CEJC co-sponsored AB 871 in 2025 to clarify and strengthen mandated reporting responsibilities of bank personnel.
Along with outreach to stakeholders and highlighting innovations, the A*Team has developed guidance for MDTs working with banks and an MDT resource page providing updated training and guidance materials for multidisciplinary teams.
The A*Team project was funded through a three-year grant from the USDOJ Office for Victims of Crime.
Addressing Systemic Barriers to Elder Justice
CEJC’s A*Team Tackles MDT/Bank Interactions During Investigations
The Problem
Multidisciplinary teams report one of the most common obstacles to financial exploitation investigations is the lack of bank compliance with requests for customer records that are needed as evidence. The A*Team worked to identify solutions to address the banking industry’s reluctance to comply with investigator’s record requests. Internal bank protocol and regulatory restrictions make it difficult for them to stop transactions when an account holder insists the payment is legitimate or to communicate with the bank receiving the funds. Understanding the factors contributing to these hurdles were key to finding a solution.
The Legal Framework
Banks are authorized to comply with investigators’ requests by multiple privacy exemptions in state and federal law and under different regulatory authorities, which appear to confuse, rather than clarify, the responsibility.
- State-chartered banks are regulated by both state and federal law.
- California law exempts banks from liability for sharing customer records during law enforcement and Adult Protective Services (APS) investigations. Exemptions are clearly detailed in the California Financial Privacy Act (Fin. Code Sec. 4050 and 4060) and Government Code Sec. 7470 and 7480.
- Multi-state banks are primarily under federal jurisdiction. 15 USC Sec. 680 (2) is the Gramm-Leach-Bliley provision exempting all banks from liability for releasing customer account records during law enforcement investigations.
- California Welfare and Institutions Code (WIC) 15630.1 states that all bank officers and employees in the state are mandated reporters of elder abuse.
- Mandated reporters are liable for failure to report suspected financial elder abuse under WIC 15630.1 (f) and face penalties of up to $5,000 to be paid by the financial institution that employs the individual who failed to report. Should we add something about the fact that this amount is too small to make a difference.
- Under WIC 15610.30, financial institutions may be held liable for elder “financial abuse” if the institution assisted in a transaction that the bank officer “knew or should have known that (the transaction) was likely to be harmful to the elder or dependent adult.
Additionally, banks are authorized to hold certain suspicious transactions for up to 15 days under Welfare and Institutions Code 15630.2 (j)(1). The law allows a court order to extend the bank hold at investigators’ request. Welfare and Institutions Code 15630.2 (j)(4) exempts a mandated reporter of suspected financial abuse from civil liability for delayed transactions held in good faith.
Many banks cite liability concerns when declining investigators’ requests, despite the state and federal statutory exemptions. Banks also require reports of suspicious or known fraudulent activity to be approved by management or legal counsel before reports can be filed, creating a direct conflict with the individual employee’s mandated reporting duty and without regard for their own liability for failure to report.
Partnering with the County Welfare Directors Association, CEJC co-sponsored AB 871 in 2025, to clarify and strengthen mandated reporting responsibilities of bank personnel.
A*Team Recommendations
1. Possible solutions to address these challenges include:
- Including bank representatives on multidisciplinary teams.
- Develop a standardized protocol for MDT coordinators to follow in outreach and relationship-building with bank officials in order to establish trusted points of contact before investigations are required.
- Amend California law to simplify and clarify requirements around mandated reporting and records sharing.
- Explore and promote federal solutions to strengthen large, multi-state banks’ compliance with individual state’s mandated reporting laws.
- Establish a single point of contact or Ombudsman in the State Attorney General’s Office to help resolve issues and/or to assist local law enforcement.
- Require banks to designate a primary contact for APS and Law Enforcement investigators to work with during investigations.
To learn more about the A*Team or to request ongoing updates, email [email protected]