Ken Golliher is a principal with Pegasus Educational Services, LLC., a training firm organized in 1996 with headquarters in Louisville, Kentucky. Pegasus specializes in technical and regulatory instruction for financial institution personnel. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection school for examiners. Ken has also been an instructor at compliance schools sponsored by the Illinois, Georgia, Indiana and Nebraska bankers associations.
03/04/2018
Our BSA officer insists when a customer deposits or withdrawals over $5,000 in cash, we have to ask what the cash is being used for. Is there regulation to support this? I understand CDD, but isn't this taking it too far? Is it our job to be nosey?
02/25/2018
Should a new Beneficial Owners Certification form be completed every time a new account is opened if there have been no changes in the beneficial ownership of the legal entity? Can the certification form currently on file be copied, re-signed and re-dated rather than complete a whole new form in those instances?
02/04/2018
A corporate CD signer passed away. The daughter and son would like to be added to said CD. On the State of Florida's Division of Corporations web site, both son and daughter are registered for the corporation. The daughter shows as a registered agent, and the son as officer/director plus there is a third person who is also as officer/director. Can we add the daughter and son as signers on CD? Do we have to add the third person as well, or does a court document and/or trust need to be presented showing son/daughter/3rd person as either owners/trustees before adding the names?
02/04/2018
I have asked a new customer to provide the business partnership agreement as part of my new account required documentation in order to open a business account. However, the customer is adamant that under partnership law, the general partner has the authority to direct its affairs. We can confirm both entities were organized in Texas on the Secretary of State's website. The customer says that should be sufficient for our requirement. Where can I confirm that it is not required to obtain?
02/04/2018
Can a financial institution run Chexsystems on a business? Or do we run Chexsystems on all beneficial owners and signers upon written consent?
02/04/2018
We have numerous business accounts that have accounts for the state lottery. Is there anything we are required to get per regulation from the business, i.e. lottery license?
01/21/2018
Does Reg P require the initial Privacy Policy Statement be signed by the client? I am not able to find anywhere that states that is a requirement. If not, how is a bank to document the file that it was given to the client at the time the client established a relationship with the Bank?
01/21/2018
Can a stop pay be placed on a cashiers check?
01/14/2018
On interest bearing accounts, must a bank whether in person or via online e-disclosures provide a rate sheet to their clients or is this discretionary?
01/07/2018
I am looking to incorporate some language within our membership handbook under the PATRIOT Act notice on questioning certain banking transactions. I have been searching the web but having difficulty finding anything. Something along the lines that " We may contact you regarding certain transactions that appear out of normal pattern", etc. Basically I would like to cover us for when we do reach out to a customer on unusual or just unexplainable transactions that do not appear usual?