Comprehensive Policy for Serving Senior Clients

1. Purpose

This policy outlines Holistic Capital's commitment to providing high-quality advisory services to clients over the age of 65. It includes guidelines for identifying and managing situations where a client may experience diminished capacity, as well as measures to prevent financial exploitation.

2. Identification of Diminished Capacity

• Training: All advisors and staff at Holistic Capital must undergo training to recognize the signs of cognitive decline, which may include:
  • Confusion or difficulty understanding financial concepts.
  • Unexplained changes in financial behavior or spending patterns.
  • Forgetfulness or repeated questions about previously discussed matters.
• Documentation: Any observations of potential cognitive decline should be documented and reviewed with the compliance team to determine appropriate action.

3. Communication with Clients

• Clear Communication: Advisors should use clear, straightforward language when discussing financial matters with senior clients, avoiding jargon and ensuring that clients fully understand their investment options.
• Regular Check-Ins: Schedule regular reviews with senior clients to assess their financial plans, answer questions, and adjust strategies as needed based on their changing circumstances.

4. Establishing Trusted Contacts

• Trusted Contact Requirement: Advisors must ask each senior client to designate a trusted contact person who can be notified in the event of suspected cognitive decline or potential financial abuse.
• Role of the Trusted Contact: This person will be contacted only when there are concerns about the client's well-being or ability to make sound financial decisions.

5. Protection Against Financial Exploitation

• Monitoring for Unusual Activity: Regularly monitor senior client accounts for unusual transactions, large withdrawals, or changes in spending patterns that could indicate potential exploitation.
• Action Steps: If financial exploitation is suspected, the advisor must immediately report the situation to the compliance officer for further investigation and take appropriate steps to protect the client's assets.

6. Client Education

• Educational Resources: Provide senior clients with educational materials on topics such as retirement planning, estate management, and fraud prevention.
• Workshops and Webinars: Offer workshops or webinars that focus on issues relevant to senior clients, such as avoiding scams or understanding investment risks.

7. Compliance with Regulatory Requirements

• Ethical Standards: Holistic Capital will adhere to all applicable regulatory standards related to serving senior clients, including maintaining confidentiality and transparency in all interactions.
• Periodic Review: This policy will be reviewed annually to ensure that it meets the latest industry standards and regulatory guidelines.

8. Response Plan for Diminished Capacity

• Documented Procedures: Establish a clear response plan for situations where a client’s capacity is in question. This may include involving the trusted contact or adjusting the client’s investment strategy to reduce risk.
• Legal and Ethical Considerations: Ensure that all actions taken are in line with legal requirements and uphold the client's best interests.