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  1. Comprehensive Policy for Serving Senior Clients

  2. Purpose
  3. 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.

  4. Identification of Diminished Capacity

  1. Training: All advisors and staff at Holistic Capital must undergo training to recognize the signs of cognitive decline, which may include:
    1. Confusion or difficulty understanding financial concepts.
    2. Unexplained changes in financial behavior or spending patterns.
    3. Forgetfulness or repeated questions about previously discussed matters.
  2. Documentation: Any observations of potential cognitive decline should be documented and reviewed with the compliance team to determine appropriate action.
  1. Communication with Clients
  1. 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.
  2. 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.
  1. Establishing Trusted Contacts
  1. 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.
  2. 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.
  1. Protection Against Financial Exploitation
  1. Monitoring for Unusual Activity: Regularly monitor senior client accounts for unusual transactions, large withdrawals, or changes in spending patterns that could indicate potential exploitation.
  2. 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.
  1. Client Education
  1. Educational Resources: Provide senior clients with educational materials on topics such as retirement planning, estate management, and fraud prevention.
  2. Workshops and Webinars: Offer workshops or webinars that focus on issues relevant to senior clients, such as avoiding scams or understanding investment risks.
  1. Compliance with Regulatory Requirements
  1. Ethical Standards: Holistic Capital will adhere to all applicable regulatory standards related to serving senior clients, including maintaining confidentiality and transparency in all interactions.
  2. Periodic Review: This policy will be reviewed annually to ensure that it meets the latest industry standards and regulatory guidelines.
  1. Response Plan for Diminished Capacity
  1. 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.
  2. Legal and Ethical Considerations: Ensure that all actions taken are in line with legal requirements and uphold the client's best interests.
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