Both the initial and refresher elder financial exploitation training programs should be at least thirty minutes long.
The Illinois Administrative Code establishes the length and content requirements for elder financial exploitation training. It does not distinguish between the initial and refresher training, which should be at least thirty minutes in duration (among other requirements). Accordingly, we do not believe courses that are five, ten, or fifteen minutes long would fulfill the requirements for refresher training under the Illinois Administrative Code.
The Illinois Department of Financial and Professional Regulation has released a list of courses that have been reviewed and deemed to meet the requirements of the rule. One of the courses listed is the “Bank Administration Institute Elder Financial Abuse Definition and Prevention Course.”
It appears that BAI currently provides a thirty-minute course titled “Elder Financial Abuse: Detection and Prevention.” We recommend that you check with the BAI to confirm that this course meets the requirements outlined by the Illinois Administrative Code before purchasing.
For resources related to our guidance, please see:
- Financial Exploitation Training, 89 Ill. Adm. Code 271.120(d) (“Current employees and officers of a financial institution on August 1, 2011 who have direct customer contact must satisfactorily complete financial exploitation training by February 1, 2012 and complete refresher training every three years thereafter.”)
- Financial Exploitation Training, 89 Ill. Adm. Code 271.120(e) (“New employees and officers of a financial institution who are hired after August 1, 2011 and who will have direct customer contact must satisfactorily complete financial exploitation training within 6 months after entering into new or different positions and complete refresher training every three years thereafter.”)
- Financial Exploitation Training, 89 Ill. Adm. Code 271.120(b) (“The training may be by in-person training or other media, such as a DVD, video tape or the Internet, and it must be at least 30 minutes in duration.”)
- Financial Exploitation Training, 89 Ill. Adm. Code 271.120(c) (“Completion of the B*SAFE (Bankers and Seniors Against Financial Exploitation) training program, developed by the Department on Aging, may be used to satisfy the training requirements of this Section.”)
- IDFPR, FAQs About the Financial Exploitation of the Elderly Training Requirement Rule (January 23, 2012) (“Are there some courses that have been determined to meet the requirements of the rule? Yes. The following courses have been reviewed and deemed to meet the requirements of the rule: . . . Bank Administration Institute Elder Financial Abuse Definition and Prevention Course. . . .”)