10.12.2. Delay of Disbursements
The Model Act allows an IA or BD to delay disbursing funds from an account if the disbursement is reasonably believed to be an attempt at financial exploitation. If an IA or BD takes this step, it must follow up by:
• Notifying every person authorized to transact on the account, in writing, within two business days. An exception is anyone suspected of involvement in the financial exploitation, who must not be notified.
• Notifying Adult Protective Services and the state securities commissioner within two business days.
• Conducting an i