In 2008, here's what some firms did to capture transactions, practices that may impact seniors firms:

• Maintain trade blotters contain account information - e.g., age, net worth, investment objective - alongside the transactions for ease in supervisory review.”
• Restrict high-risk trading for investors over a certain age unless pre-approved.
• Use exception reports to isolate activities and accounts for additional review - e.g., IRA distributions above the minimum required distribution, 1035 exchange transactions, investors over a certain age that list “speculative” as an investment objective.   [“1035 exchanges” are so named because IRS Code Section 1035(a)(3) provides that no gain or loss shall be recognized on the exchange of one annuity contract for another annuity contract.]
• Require that all 1035 exchanges and 72T distribution requests be approved by a direct supervisor and a central review unit.
  
• Block transactions if the surrender charge is greater than a pre-determined amount.

Some exception reports "ID accounts or investors over a certain age" who may risk encountering portfolio allocations, commissions, and other issues: 

• Those accounts generating a commission-to-asset ratio above a certain percentage.
• Those accounts generating commissions in speculative or complex investments.
• Those accounts having “conservative” or “income” as an investment objective, but have margin above a certain threshold, and/or have option trading losses.
  
• Those accounts with concentrations or margin balances.
  
• Those accounts of investors who are over a certain age, or of any age, in which a change in trading activity has occurred and a POA has recently been added or amended.
  
• ID investors over a certain age with IRA rollover accounts.

Some reviews target for inappropriate or abusive activities, such as: 

• RRs selling a threshold number or annuities to investors over a certain age during a specified period.
• RRs selling a threshold number or annuities with the same rider.
• RRs having an inordinately large number/percentage of senior investor accounts.
• RRs generating higher commissions from senior investor accounts.
  
• RRs having inordinately high rolling-month fees generated by senior investor accounts. 
  

For further details, click onto:  [ SEC PR 10-147, 8/13 ];  and, [ The 2010 Addendum ];  and  [ The 2008 Report ]

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The above info came from "Protecting Senior Investors:  Compliance, Supervisory and Other Practices Used by Financial Services Firms in Serving Senior Investors," guidelines from the staffs of SEC's OCIE, FINRA and NASAA - published in 2008, updated in 2010. 

Here's what C-I is focusing on.  Next posting deals with #6.

1. Getting started: how firms are thinking of ways to remodel their supervisory and compliance structures to meet the changing needs of senior investors.
2. Communicating effectively with senior investors.
3. Training and educating firm employees on senior-specific issues (such as how to identify signs of diminished     capacity and elder abuse).  
4. Establishing an internal process for escalating issues and taking next steps. 
   
5. Advertising and marketing to senior investors.
6. Obtaining information at account opening.
7. Conducting senior-focused supervision, surveillance and compliance reviews.