This protocol and manual has been created in order for Oriental (the “Bank”) to comply with the provisions of Regulation 9368 promulgated by the Commissioner of Financial Institutions of Puerto Rico (“OCIF” in Spanish), by establishing the procedures for all branches and the Bank’s Compliance Unit, which must be followed to prevent, detect, investigate and report possible cases of financial exploitation or abuse against bank customers who are of Elders or Disabled Person (further referred to jointly as “vulnerable person”).

Financial exploitation can be committed by, scammers, a family member or even the guardian of a vulnerable person.

1. A vulnerable person goes to the bank accompanied by a person, whether a family member or not, who incites or coerces him or her to make a withdrawal, money transfer, loan or other transaction.
2. A vulnerable person goes to the Bank accompanied by a person, whether a family member or not, who does not allow them to talk directly with bank personnel.
3. A vulnerable person appears dazed, nervous, or afraid.
4. A vulnerable person does not remember certain financial transactions in his or her account(s) or claims not to have authorized one or more transactions and shows concern or confusion about it.
5. A vulnerable person shows concern or confusion over the balance sheets of his or her account(s).
6. A vulnerable person goes to the Bank accompanied by a person, whether a family member or not, that appears to be overly interested in his or her financial statement.
7. A vulnerable person (or someone else) offers contradictory or questionable explanations for financial transactions.
8. A vulnerable person appears fearful of being evicted or committed to an institution if he or she does not give money to the person in charge of his or her care.
9. A vulnerable person, in physical appearance, looks like he or she is not receiving required care, according to his or her needs and financial condition.

1. A person or a family member who consistently seeks guidance on financial benefits for a vulnerable person without his or her consent.
2. More than one person or family member claims to have guardianship over a vulnerable person and his or her property.
3. A person claiming to have custody or to have been designated as the authorized person to handle a vulnerable person's accounts refuses to show proof of his or her authority or provides contradictory proof.
4. Falsifies the signature of the elderly or disabled person.
5. Use the elderly or disabled pension or insurance money for his or her own benefit.
6. Without the elderly or disabled's consent, the exploiter requests a change of residential or mailing address from the one previously reported by the elderly or disabled person, closes bank accounts, withdraws large sums of money from his or her accounts or cancels all of his or her insurance.

Puerto Rico Law No. 206 of 2008, provide civil immunity to any person who in good faith provides to any law enforcement agency information about any act relating to financial exploitation.

Oriental has a protocol to refer financial exploitation cases to the relevant agencies and our employees are trained to identify suspicious behavior or unusual banking activities that could indicate financial abuse against an elderly or disabled person.