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.
06/10/2018
How can a "Statutory" trust be differentiated from a regular trust? What specifically should be present for a trust to be a statutory trust and is it just the fact that there is a filing with the Secretary of State?
05/27/2018
We have recently discovered that a few CTRs were filed with a (1) transposed number on the customer's drivers license (teller error). We have corrected the issue and were not sure if we should amend the CTRs that were filed with a number off, or consider this information "not-critical" and proceed by filing with the corrected number from now on?ken
05/27/2018
Wrapping my head around NGO and Charities and the Beneficial Owners. The Non for profit Business. Like an Electrical Company (which is listed on the guidestar site) and on the NAICS as a utility. Would need to fill out both forms? But, with the electrical company having so many members that the 25% would not apply?
05/20/2018
At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?
05/20/2018
We are needing to know what an expired W-8BEN means to the bank, is it a big deal? If so what should the time frame be to get a current W-8BEN from the customer and what should the consequence be if the bank does not receive one?
05/06/2018
Reclamations from the VA and SS are arriving late - funds are gone, the joint owner (spouse) already withdrew the funds. We fill out the notice when it arrives and explain "no funds." then months later they pop back in withdrawing the funds. Have you had any success in fighting this?
05/06/2018
Can we offer a Money Market account, but restrict withdrawals to face to face transactions or transfer to another account within our bank? That would mean no access to withdrawals by check, ACH or debit card.
05/06/2018
Regarding CTR forms, what is the definition of "Shipment" on box 24c "Mail Deposit or Shipment." Looking for clarification of when this would be utilized?
05/06/2018
If Bank receives a copy of a DL for a Beneficial Owner that has a different address than supplied on the collection form or the Bank is only provided a passport with no address, would we need to collect other documents to prove address and/or social? I feel like we would be criticized for only being able to verify two out of four pieces of identification.
04/29/2018
I have a few questions about the 5th Pillar. My questions are: - Do we need to collect the percentage of ownership of each person signing or just know that all those signing are over 25%? - What’s considered a ‘new customer’? If the same business already has a DDA account with us, can we use the same form already filled out or do we have to have them fill out a new one? - Does this apply to existing and new customers ie. if a change is made to an existing DDA for a business that’s been with us for 100 years, do we need to fill one of these out for them?