The most appropriate permitted initial step is to contact the customer directly to confirm the activity and, if needed, notify the customer’s trusted contact person, making D correct. FINRA guidance and firm practices around protecting seniors emphasize proactive steps to detect and respond to potential financial exploitation. A trusted contact is a person the customer authorizes the firm to contact if there are concerns about possible exploitation, diminished capacity, or suspicious activity. Reaching out to the customer helps verify whether the activity was authorized and consistent with their intentions, and involving the trusted contact (when appropriate and permitted) adds another protective layer.

Choice A is inappropriate because immediately closing an account is an extreme action that is not the standard first step and could harm the customer or disrupt legitimate needs. Choice B is also inappropriate because liquidating assets without authorization is generally impermissible absent a clear legal basis, proper discretion, or a valid protective hold process under firm policy and applicable rules. Choice C is not the correct initial step; while firms may have reporting obligations in certain circumstances, the immediate first response is typically internal escalation and customer contact rather than “reporting to FINRA and the SEC” as the first action.

On the SIE, this tests senior investor protection concepts: recognizing red flags, escalating internally, and using tools like the trusted contact to help protect vulnerable customers while respecting account authority and documentation requirements.