Yes, we believe it would be permissible to report the amount of money withdrawn from your customer’s account when voluntarily reporting suspected elder financial exploitation.

Both Illinois and federal financial privacy laws include exceptions that permit you to reveal certain customer information in this situation. Illinois law does not define what information you may reveal, but we believe it is permissive enough to permit you to report the amount of money withdrawn from your customer’s account. The Illinois Banking Act privacy provisions allow you to report any “information . . . if there is suspicion by the bank that a customer who is an elderly or disabled person has been or may become the victim of financial exploitation.” 205 ILCS 5/48.1(b)(16). Federal law is more helpful, as it defines what information may be revealed. Regulation P permits you to report “nonpublic personal information” when needed “to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.” 12 CFR 1016.15(a)(2)(ii). “Nonpublic personal information” is defined to include a customer’s account balance and payment history, and we believe that this permits you to report the amount of money withdrawn from your customer’s account. 12 CFR 1016.3(q).