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.
We have a customer that has brought in a decree approving first and final accounting and closing of an estate. The administrator has asked us to cut 3 separate checks to the heirs listed in the document. Our issue is the administrator never moved the money into an estate account. It is still in the name of the deceased. Should we ask them to open an estate account just for the disbursements or would it be ok to do it directly from the deceased account?
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
314a searches need only encompass current accounts and accounts maintained by a named subject during the preceding twelve (12) months, and transactions not linked to an account conducted by a named subject during the preceding six months. How is the information handled for named accounts older than 12 months and with no other relationship?
We have looked at Reg DD but cannot find where it even mentions this.
Are we required to tie IRA rates (variable or fixed) to an outside index? I think that back in the 1980’s when they first became available, it was a
But I cannot find it mentioned anywhere now?
I understand that businesses are exempt from the overdraft protection opt-in requirements but, am uncertain if the exemption covers Trust accounts and Estate accounts in that "personal, family or household" exemption?
Is a canabidiol (CBD) business legal at the Federal level. I understand it is legal in all 50 states but unsure about the Federal level. Would it be treated the same as a marijuana related business where a continuing SAR would be required?
A customer was depositing a Not On Us check for $1500 into his checking account for $1200 and was supposed to receive $300 cash back from the transaction. The teller mistakenly keyed $1500 into the cash recycler and handed the cash directly to the customer. This is proven by video surveillance and the reporting tool from the cash recycler, which shows the denominations of the bills he received. The cash back totals $1500, is time stamped for when he is at the teller window and has the teller #. Is this sufficient proof so that the Bank can the bank legally debit his account for $1200? The customer has hung up on bank employees when we have attempted to contact him.
Best practice for closing and reopening IRA and or CD accounts in new beneficiary names due to death. Should we keep the same rate or give the current rate which is less?
What method of identification do you use for a minor on a CTR?
What types of accounts are offered to charitable organizations? Can they open a money market account and what are the money market eligibility requirements?