Networks and the EJCC

At the federal level, elder justice networks are advanced by the Council and facilitated by designated federalism officials in agencies (Executive Order 13132), who recognize that “‘State and local officials’ means elected officials of State and local governments or their representative national organizations” (Section 1(d)).

Through networks, state and federal agencies help impart personal agency to concerned citizens and communities countrywide. Just as our “united states” are all-stars of different stripes, so are citizens, whose diversity imparts strength to our networks.

Jay A. Mancini, and Karen A. Roberto (2009, 254) observe:

“When dissimilar networks focus on common issues, the odds increase of making positive differences in communities…networks provide the framework for social action because it is through networks that community members develop relationships and feel connected to one another.”

Mancini and Roberto elaborate, “Community capacity aspects of social organization focus on the development of informal social networks to enhance community life and move communities closer to achieving their desired results, including community resilience” (2009, 247).

Like the warp and weft in a fabric, formal networks create structure and guidance, while informal networks create cohesion and strength. Together they weave a social safety net. Respectively and respectfully, they fashion our social fabric.

Networks are vital for communication, cooperation, and capacity. Yet, until recently, our understanding of “elder abuse” was hampered by its anti-social companion dyad “elder-abuser” at the expense of a more pro-social, engaged, networks-driven response to this social harm.

Elder justice efforts have been informed by social exchange theory, which was initially focused on dyadic exchange relations, too — until the publication of Richard M. Emerson’s seminal 1972 works on exchange network theory, including Exchange Relations and Network Structures. Fifty years on, robust research and practice have underscored the vital role of networks.

“The key to understanding people is understanding the ties between them; therefore, it was to the ties that we turned our focus,” write Nicholas A. Christakis and James H. Fowler in introducing Connected: T he Surprising Power of Our Social Networks (2009, 8).

The Consumer Financial Protection Bureau (CFPB), a Council member, has significantly enhanced our understanding of networks and their practical application to advance elder justice, together.

CFPB’s Office for Older Americans has helped establish and fortify collaborative networks through its Elder Fraud Prevention and Response Networks initiative, which “brings together key stakeholders and resources to prevent, detect, and respond to elder financial exploitation in the community.”

Generally, “a network…is a sustained and largely voluntary collaboration, coalition, alliance, or partnership of private and public entities, organizations and individuals that works with or on behalf of older people.” (CFPB, May 2018, 11)

In 2015, CFPB’s nascent network initiative was informed by a year-long study, Fighting Elder Financial Exploitation through Community Networks: Report and Recommendations (August 23, 2016), that included research and recommendations to guide CFPB and networks nationwide. In 2017, CFPB embarked on a network development initiative that included Report and Recommendations: Fighting Elder Financial Exploitation through Community Networks and a companion, A Resource Guide for Elder Financial Exploitation Prevention and Response Networks (May 2018). In 2019, CFPB offered a webinar (May 30, recording, transcript). In 2020, CFPB released the Elder Fraud Prevention Network Development Guide, which “provides step-by-step materials to help communities form networks to increase their capacity to prevent and respond to this crime.”

CFPB has developed robust resources for stakeholders to reconvene and establish a network, and expand capabilities. The guide contains downloadable resources, including templates, fillable worksheets, checklists, discussion guides, tips for networks, and much more — all spurred and facilitated by examples of network goals, action steps, and demonstrated success.

Citizens seeking existing networks can search the Elder Justice Network Locator (U.S. Department of Justice) to locate local and state organizations, agencies, and coalitions. Two points of contact in communities include those who serve and save: the country’s six-hundred-plus area agencies on aging, represented by USAging, whose “members help older adults and people with disabilities throughout the United States live with optimal health, well-being, independence and dignity in their homes and communities”; and state adult protective services (APS) programs, represented by NAPSA, whose mission is to “strengthen the capacity of APS…to recognize, report, and respond to the needs of elders and adults with disabilities who are the victims of abuse, neglect, or exploitation.”

In 2023, the CFPB Office for Older Americans launched a webinar series titled Promising Practices from Successful Elder Fraud Prevention and Response Networks. Co-leaders include webinar series host Jenefer Duane, senior program analyst and program manager, elder fraud prevention and response networks program, and Lisa Schifferle, senior policy analyst, Office for Older Americans. The goal of the ongoing series is to convene seemingly disparate stakeholders to explore how they can build or augment collaborative networks to prevent and resolve cases of elder financial exploitation. The series is prefaced with New Resources for Elder Fraud Prevention and Response Networks. (February 1, 2023; recording, slides) Efforts were chronicled by experts from Michigan, South Carolina, New York, Hawai’i, and Florida. A sea change is evident from coast to coast, to coast, to coast, to coast, extending into our heartland, which blankets and feeds us.

The Promising Practices Part 1 webinar featured network leaders who addressed strategies for funding elder justice networks, cross-discipline training, and more. Network speakers included Jennifer Blanck (Michigan Elder Justice Coordinating Council), Scott Ehlfeldt (Prosecuting Attorneys Association of Michigan); Susan Ingles (South Carolina Legal Services), and Kay Hightower (South Carolina Department of Aging).

In closing, Paul L. Caccamise, vice president for program at Lifespan of Greater Rochester, highlighted the Office for Victims of Crime, Office of Justice Programs at the U.S. Department of Justice. The agency funded an initiative, “Transforming America’s Response to Older Victims: Developing and Supporting Statewide Elder Justice Coalitions and Training and Technical Assistance Program,” which supports Lifespan, an organization that serves as the lead agency of a consortium of elder justice organizations and specialists, all aiming to realize the project’s stated intent, state by state.(February 8, 2023, recording, slides)

The Promising Practices Part 2 webinar featured network leaders who addressed how state-level elder justice networks effectively support locally based sub-networks and more. Network speakers included: Brian Ishikawa(Bank of Hawai’i), Mary Gilmeister (Macha), Leslie Andrews (Elder Options, Florida), and Amy Thomas (Elder Options). (February 15, 2023, recording, slides)

The CFPB Elder Fraud Prevention Network Development Guide and companion training continue to help communities countrywide to plan, convene, host, establish networks, expand network capabilities, and harness network resources.

Harness the third sector 

For elder justice, communication and cooperation among sister states is being achieved by the self-descriptive, nascent National Network of State Elder Justice Coalitions (NNSEJC, National Network), launched in 2018 by a founding six-member steering committee representing five states. Each coalition member presented on its respective programs during a panel at the American Society on Aging conference. The National Network then put out a call to see if there were other state coalitions and invited them to join in. Personnel from the U.S. Department Justice have participated on the National Network’s advisory committee.

As described by the National Network’s founders in Building a National Elder Justice Movement, State by State (Generations, Journal of the American Society on Aging, Spring 2020, vol. 44 no. 1, pp. 111–116):

“The purposes of the group are five-fold: to help statewide elder justice coalitions with multiple professional constituencies attain their common goals; to collect and make available innovative models and strategic approaches to strengthen members’ capacity and program efforts; to generate networking opportunities for state elder justice coalitions; to assist new multidisciplinary state elder justice projects to develop broad-based sustainable coalitions; and to address state elder justice coalitions’ roles in public policy.”

Let’s not be ageist about the youth of the NNSEJC and its capacity. It’s gaining ground nationwide. It has also helped serve as a catalyst for a fast-growing initiative among sister states, spurred by the U.S. Department of Justice. Reported by the DOJ Office for Victims of Crime:

“In October (2022), the U.S. Department of Justice awarded a three-year, $3,750,000 grant to Lifespan of Greater Rochester, New York, that ‘…will serve as the lead agency of a consortium of elder justice organizations and specialists with many years of experience and depth of expertise in the field to establish a [center].’ The National Center for State and Tribal Elder Justice Coalitions [NCSTEJC] at Lifespan of Greater Rochester (hosted by the New York State Coalition on Elder Abuse), in collaboration with the U.S. Department of Justice (DOJ) Office for Victims of Crime, was established in October 2022. On April 3, 2023, the center announced a Request for Proposals for funding to establish new statewide or tribal elder justice coalitions or to enhance the operation of existing coalitions.”

As presented by Paul L. Caccamise during an Office for Older Americans, Consumer Financial Protection Bureau webinar (February 8, 2023), the goals of the DOJ-funded initiative are to:

• Support statewide efforts to develop new coalitions and expand existing Elder Justice Coalitions;

• Provide evidence-based, trauma-informed training and technical assistance to existing coalitions across the Nation;

• Make and monitor sub-awards to seven Coalitions to support their growth and expansion; and

• Contribute to the growth of Elder Justice Coalitions as a field of practice.

On December 15, 2023, the National Center for State and Tribal Elder Justice Coalitions at Lifespan of Greater Rochester, in collaboration with the U.S. Department of Justice, Office for Victims of Crime (OVC), announced a Request for Proposal for Program Evaluation, “to assess the achievement of project goals and the success of the center activities in supporting the growth of state and tribal elder justice coalitions through training, and technical assistance.”

Announced in early 2024, eight (of 18) coalitions were sub-awarded 2023 grants. These include: California (enhanced), Colorado (new), Maine (enhanced), Missouri (new), Rhode Island (enhanced), Texas (new), University of North Dakota: tribal (new), Wisconsin (new).

The strategic significance of statewide coalitions is emphasized in the Annual Report to Congress on Department of Justice Activities to Combat Elder Fraud and Abuse by Attorney General Merrick Garland, U.S. Department of Justice (October 18, 2022). In “A message from Kristina Rose, Director, Office for Victims of Crime, on Forthcoming Statewide Elder Justice Coalitions.” Director Rose notes:

“Older Americans are targets for multiple forms of abuse (e.g., guardianship abuse, financial exploitation, fraud, and scams) that, when coupled with age, can be barriers to accessing services… These challenges are compounded further because the victim services field has little dedicated funding to support Elder Justice Coalitions… Therefore, OVC is funding a new national training and technical assistance effort to support the development or expansion of statewide Elder Justice Coalitions…” (77)

Soon, all states will have statewide and tribal elder justice coalitions to advance citizens’ concern, capacity, and coordination through networks, spurred by the support of DOJ and sister agencies.

As exemplified and achieved by CFPB, NNSEJC, and NCSTEJC, networks help address and arrest elder abuse and financial exploitation in all arenas, including guardianship — especially when coupled with a responsive regulation approach by state and federal agencies.

Apply a responsive regulation approach 

To arrest criminal acts and regain trust, a two-pronged campaign must:

• Hold both individuals and courts accountable for the criminal consequences of their actions, toward prosecution informed by an attribution of responsibility (Schmidt, McGrimmon, and Dilks 2022, 47). For example, a primary goal of the New York State Legislature in 1986 was to deter white-collar crime by making Grand Larceny in the First Degree (New York Penal Law 155.42) a Class B felony, which imposes a mandatory prison term.

• Achieve systemic change in courts that sponsor guardianships and provide the environment for criminal acts.

Schmidt and colleagues conclude, “…the environment in which white-collar crime takes place strongly affects the attribution of responsibility for the crime and its subsequent punishment” and that strategies must focus on both “bad apples” and “corrupting barrels” (52–53; ref. Scholten and Ellemers, 2016).

Efforts must extend beyond accountability and ‘just deserts’ for individuals(Braithwaite 1982) to the prevention of abuse and exploitation by organizations such as state courts. Concurrently, efforts must extend beyond “ritualistic regulation that gives the appearance of being tough without compelling major substantive change.” (Braithwaite, Makkai, Braithwaite 2007, 220)

Deliberate and flexible responsive regulation is applicable here as long as it is understood that, in the case of guardianship, the state is regulating its own “business.” The involvement of third parties is vital. As defined and practiced by John Braithwaite:

“Responsive regulation is about ‘tripartism’ in regulation. It highlights the limits of regulation as a transaction between the state and business. It argues that unless there is some third party (or a number of them) in the regulatory game, regulation will be captured and corrupted by money power.”

Prosocial norms help mitigate such systemic social harms. Sally S. Simpson (2013, 325) recognizes that “Responsive regulation…emphasizes the moral and prosocial influences that guide potential offenders.” Simpson (324) observes:

“On the responsive regulation side, abundant research supports the notion that norms and morality shape offender decision making and that behavior can be positively or negatively shaped by how regulators respond to violators.”

Braithwaite conceptually arranges responsive regulation into two pyramids: one of sanctions and another of support, “to pick problems and fix them but also to pick strengths and expand them,” respectively. The support pyramid may include education, praise, award of grants, other incentives, and professional acclaim. The sanctions pyramid starts with less interventionist sanctions (capacity building, restorative) and, should these fail, advances to stronger sanctions (deterrence, incapacitation), “Signaling to stakeholders the capacity to escalate to ‘the tough stuff’ higher up the pyramid motivates cooperative problem solving at the base of the pyramid.” (December 14, 2022)

Simpson (2013) recognizes that “…the punishment of white-collar offenders (for individuals and companies) carries the potential for significant legal and extralegal costs. Responsive regulation, in contrast, emphasizes the moral and prosocial influences that guide potential offenders.” Simpson adds, “On the responsive regulation side, abundant research supports the notion that norms and morality shape offender decision making and that behavior can be positively or negatively shaped by how regulators respond to violators.” Moving forward, pro-social norms can help mitigate social harms.

Guardianship abuse and exploitation are state-sanctioned. Specifically, “…state-routinized activities include those expressions of ‘corruption,’ ‘extortion,’ and ‘professional theft’ that are institutionalized or legally sanctioned through legislation and court decision.” (Barak 2015)

Being a social harm, guardianship abuse and exploitation as white-collar crime extend beyond structural violence (Galtung 1969), which “describes social structures… that stop individuals, groups, and societies from reaching their full potential” (Canning and Tombs 2021, 57) to include institutional violence, which is “a form of violence that can be understood as a means of force which is not simply acted upon, but organized and administered through legitimate means” (Cooper and Whyte 2017, 23; in Canning and Tombs).

Proactive and preventive approaches recognize that “crime is not just a question of who breaks the law, but also about who makes the law and how it is enforced.” (The Open University, accessed 12/14/22) To date, “the striking gap between law and practice has been daunting for advocates seeking to strengthen individual rights and ensure accountability,” as expressed by the ABA Committee on Law and Aging in its guardianship-focused WINGS Briefing Paper, supported by ACL (c. 2020, 8).

Regulatory efforts toward systemic reform of guardianship through legislation will work when coupled with greater interventionist sanctions of bad actors, in part through severe, swift, and certain punishment — including time served in moderate or maximum security prisons, fines, restitution to victims (or their legatees), loss of professional licenses, and private lawsuits.

For white-collar criminals, prison environments will lend new meaning to guardianship. In Convenience Triangle in White-Collar Crime, Petter Gottschalk explains special sensitivity hypothesis, which “suggests that white-collar criminals suffer much more from incarceration than regular street criminals” (2019, 89). Gottschalk elaborates:

“The special sensitivity hypothesis may seem particularly relevant in prison settings that suffer from poor management and that experience high levels of inmate violence and other forms of victimization. In such environments, white-collar inmates can prove to be attractive targets for other inmates, while at the same time they suffer from neglect by lack of guardianship(Stadler et al., 2011).”

The numbers numb us 

In guardianship, the numbers, or lack of numbers, numb us.

Financial exploitation lies at the heart of most guardianship abuse, making individuals under guardianship not just collateral damage but the deliberate targets of predatory actions. Data is available that documents the vast wealth of older adults. But states have no idea how many of their citizens are subject to guardianship and how they are being treated or mistreated. Or if they have died — at times, prematurely.

Despite repeated calls for attention, states have no idea how many persons are subject to guardianship across America. “The collection of reliable data is besieged by a number of problems,” observes the Center for Elders and the Courts, National Center for State Courts (2023). “The extent of elder abuse [financial exploitation, included] by guardians nationally is unknown due to limited data on the numbers of guardians serving older adults, older adults in guardianships, and cases of elder abuse by a guardian,” reports the U.S. Government Accountability Office (2016).

With reference to the “1.3 million” citizens subject to guardianship, David Godfrey notes, “ …that is the same guess on how many guardianships that we have been hearing for 30 years.” The probable figure is much more. States have no idea. Godfrey concludes, “…the bottom line is that in nearly every state there is no reliable data on how many adults have a guardian, what the needs of the person are and how those needs are being met” (2022, 97). This harsh reality is an indication that courts cannot be trusted to achieve change alone — or to serve and save our most vulnerable citizens today.

Due in part to the nefarious nature of this white-collar crime, such data is unavailable. Close connections and even collaboration among actors in the court system, which appears to be intentionally obscured by insufficient data and accountability, allow almost all guardianships—good and bad—to be inadequately monitored.

The lack of reliable guardianship data and monitoring has many consequences. It conceals abuse and exploitation, obscures oversight, discourages reporting, obstructs investigations, conceals trends, inhibits research and evaluation, hinders policy development and legislation, impedes resource allocation, undermines public trust, and places older adults at risk.

Guardianship is shrouded in a veil of secrecy and a lack of accountability. This raises a series of unsettling questions, prompting citizens to wonder if there is an underlying motive to conceal the true extent of guardianship practices. Why is it so difficult to ascertain the exact number of individuals under guardianship across the country? Why are guardianship hearings often conducted ex parte, excluding interested parties and limiting the ability of stakeholders to monitor and intervene? Why does the practice of annual reporting exhibit low compliance, inconsistency, tardiness, and poor quality—even though it is mandated in most states?

The lack of reliable data appears to be intentional and instrumental to guardianship as a state-sponsored white-collar crime. Congressman Claude Pepper’s stark words, uttered at his 1987 congressional hearing Abuses in Guardianship of the Elderly and Infirm: A National Disgrace, continue to resonate in this vacuum of accountability:

“The typical ward has fewer rights than the typical convicted felon… By appointing a guardian, the court entrusts to someone else the power to choose where they will live, what medical treatment they will get and, in rare cases, when they will die. In one short sentence, it is the most punitive civil penalty that can be levied against an American citizen, with the exception…of the death penalty.”

The number of persons in prison is tracked through the Bureau of Justice Statistics (BJS), the primary statistical agency of the U.S. Department of Justice, Office of Justice Programs. According to BJS, there were 1,230,100 individuals incarcerated in adult correctional facilities in the United States on December 31, 2022. This total includes individuals under the jurisdiction of state and federal correctional authorities. Meanwhile, the number of individuals under guardianship remains unknown. In Maine, for example, “Probate courts only recently began keeping track of guardianships. Several do not know how many people are under guardianship in their county, or if these adults are alive or dead,” reports Samantha Hogan of The Maine Monitor (December 17, 2023).

BJS can play a pivotal role in tackling guardianship abuse and exploitation through enhanced data collection on the number and well-being of persons subject to guardianship. Although guardianship falls primarily under the purview of individual states, BJS can serve as a central resource and partner to states in their endeavors to combat abuse and exploitation, improve data collection, hold bad actors accountable, and protect citizens subject to or vulnerable to guardianship.

BJS has explored elder abuse for years. Crimes Against the Elderly, 2003–2013, examined “patterns of victimization over time” (Rachel E. Morgan and Britney J. Mason, 2014). More recently, in 2017 BJS funded a granular third-party study by the Urban Institute (Kamala Mallik-Kane and colleagues, 2021, 1) in recognition that:

“Traditional crime statistics underestimate the occurrence of elder abuse and lack the detail required to fully understand and prevent this form of victimization. Because Adult Protective Services (APS) agencies are often first responders to elder abuse, this study examined the use of APS data as an alternative metric to monitor the scope of the problem and plan for future needs as the U.S. population ages.”

Informed by the CDC (2014), BJS taxonomy considered six forms of interpersonal elder abuse “in which there is an expectation of trust between the victim and perpetrator” (35). These included financial abuse and exploitation that, in turn, included “improper use of guardianship.” (31) “Most APS agencies (93%) gathered information on whether the alleged perpetrator had guardianship over or power of attorney for the victim.” (76) “The study found both potential for and challenges to compiling APS-based elder abuse statistics across states because of variation in elder abuse laws, agencies’ investigative jurisdictions, and data system capacity (4).

One challenge for BJS is that guardianship itself is a civil issue rather than a criminal one — even though guardianship can lead to crime. So collecting the necessary baseline data on the number of persons under guardianship is a bit outside of the BJS purview. One first step is to add a question to the National Crime Victimization Survey to ask whether an adult in the household (either with a disability or over the age of 65) is under a guardianship agreement while recognizing there are measurement challenges with this approach. This added question will also miss many individuals under guardianship living in group quarters or a nursing facility. In the latter, guardianship abuse is a chronic issue highlighted in an article titled To Collect Debts, Nursing Homes Are Seizing Control Over Patients by Nina Bernstein (January 25, 2015), for example.

In Congress, U.S. Senate Special Committee on Aging Chairman Bob Casey (D-PA) and Ranking Member Mike Braun (R-IN) urge examination of guardianship laws (May 31, 2023), in a letter to The Honorable Gene L. Dodaro, Comptroller General, United States Government Accountability Office (GAO). The senators note, “There is a lack of data on guardianships in the United States” and request “GAO examine and report on the following issues (subsections of these queries are not included here):

1. How many guardianships are currently active in the United States?

2. To what extent is NAMRS able to identify cases of elder abuse where a guardian was involved?

3. How do selected states treat petitions to end guardianships, and what challenges do states face in administering their guardianship programs?

4. When adopted by a state, what impact do the changes in the Uniform Guardianship, Conservatorship, and Other Protective Arrangements Act [at ULC] have on individuals subject to or under consideration for a guardianship arrangement?

5. What federal policies assist states in the oversight of guardianships, and how can federal policy help states seeking to adopt less restrictive alternatives such as those outlined in the ULC model guardianship law?”

Following a year-long investigation, the U.S. Senate Special Committee on Aging released a report, “Ensuring Trust: Strengthening State Efforts to Overhaul the Guardianship Process and Protect Older Americans.” (November 2018, 9; report)

“Three recurring themes emerged during the course of the Committee’s investigation: 1) the absence of consistent and reliable data related to guardianship arrangements; 2) the need for improved oversight of guardians; and 3) consideration for increased use of less-restrictive alternatives to guardianship. The Senate Aging Committee received more than 100 comments, which helped to inform its work; many of those comments are cited in this report.”

Of added interest, “In fiscal year 2021, NIJ entered into an independent consultant agreement with two subject matter experts to conduct an environmental scan of guardianship and conservatorship abuse and fraud, and identify opportunities to advance knowledge through research or data collection,” as announced by Attorney General Merrick Garland in the Annual Report to Congress on Department of Justice Activities to Combat Elder Fraud and Abuse. (U.S. DOJ, October 18, 2022)

Stop the bleeding —

States cannot do it alone. Guardianship abuse and exploitation are systemic and nationwide. These crimes demand a coordinated nationwide response, starting in each state in partnership with the federal agencies and initiatives described here.

The Elder Abuse Prevention and Prosecution Act (EAPPA via US DOJ site; Public Law 115–70; October 18, 2017), introduced by Senator Grassley, is a potential game changer. EAPPA directs that the Attorney General shall designate not less than one Assistant United States Attorney to serve as the Elder Justice Coordinator in each of the 94 U.S. Attorneys’ Offices (in federal judicial districts). Coordinator training has been partly provided the U.S. Department of Justice.

EAPPA efforts relating to elder abuse include having coordinators serve as the legal counsel for the district; prosecuting, or assisting in the prosecution of, elder abuse cases; conducting public outreach and awareness activities; and ensuring the collection of data (Title I). Coordination efforts include training agents of the Federal Bureau of Investigation (Title I); improved data collection and federal coordination (Title II); with the Office for Victims of Crime, providing enhanced victim assistance to citizens who have suffered from harm imposed by elder abuse (Title III); and imposing enhanced penalty for fraud (Title IV).

EAPPA Title V addresses court-appointed guardianship oversight activities under the Elder Justice Act of 2009.

“…programs to assess the fairness, effectiveness, timeliness, safety, integrity, and accessibility of adult guardianship and conservatorship proceedings, including the appointment and the monitoring of the performance of court-appointed guardians and conservators, and to implement changes deemed necessary as a result of the assessments such as mandating background checks for all potential guardians and conservators, and implementing systems to enable the annual accountings and other required conservatorship and guardianship filings to be completed, filed, and reviewed electronically in order to simplify the filing process for conservators and guardians and better enable courts to identify discrepancies and detect fraud and the exploitation of protected persons.”

EAPPA Title V also addresses GAO reports, outreach to state and local law enforcement, model power of attorney legislation, and best practices and model legislation for guardianship proceedings.

Separately, on March 30, 2022, the Attorney General Merrick B. Garland:

“…announced the appointment of 12 U.S. Attorneys to serve on the Attorney General’s Advisory Committee of U.S. Attorneys (AGAC). Created in 1973, the AGAC advises the Attorney General on matters of policy, procedure, and management impacting the Offices of the U.S. Attorneys and elevates the voices of U.S. Attorneys in Department policies.”

Announced on July 11, 2022, The Honorable Breon Peace, United States Attorney for the Eastern District of New York, was selected as the Chairperson of the White Collar Fraud subcommittee for the Attorney General’s Advisory Committee (AGAC).

“As the leader of the subcommittee, Mr. Peace will play a key role in making recommendations to the AGAC to facilitate the prevention, investigation and prosecution of various financially motivated, non-violent crimes including mail and wire fraud, bank fraud, health care fraud, tax fraud, securities and commodities fraud, and identity theft.”

This essay was respectfully submitted to the Administration for Community Living, representing the Elder Justice Coordinating Council, in response to the Federal Register Notice (Vol. 89, №58/Monday, March 25, 2024, Notices 20661) “Request for Information: Elder Justice Coordinating Council Priorities.” April 24, 2024.