In general, FINRA rules prohibit member firms from improper use of customer funds. One example is intentionally holding up an account transfer. Another is holding on to funds that belong to the customer. One of the features of FINRA Rule 2165 dealing with senior exploitation is the ability of a member firm to place a temporary hold on disbursements from the account of a specified adult. This serves as a safe harbor for funds held in the manner described above. A member relying on this rule must A) develop and document training policies or programs reasonably designed to ensure that associated persons comply with the requirements of this rule. B) report all temporary holds to FINRA within 15 days of the end of the month in which the hold took place. C) place temporary holds on disbursements of funds or securities from the accounts of specified adults whenever there is suspected exploitation. D) segregate customer funds from those of the firm to avoid commingling of assets.