Beneficial Ownership Rule Apply to DBA's?
04/08/2018
Does the beneficial ownership rule apply to DBA's (fictitious name registered with the Secretary of State)?
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.
04/08/2018
Does the beneficial ownership rule apply to DBA's (fictitious name registered with the Secretary of State)?
04/08/2018
Do the beneficial ownership requirements apply to an account that the bank acquires, and does it make a difference if the bank acquires it from another institution that is required to follow beneficial ownership rules or from a broker who may not be required to comply?
04/01/2018
Is use of a military ID sufficient for opening an account or doing a name change on an account? I'm looking for where Military ID's are not suppose to be used for identification, and having a hard time finding the regulations behind that or maybe I completely misunderstood and am wrongly assuming that we are not able to?
04/01/2018
We currently bank municipalities/public funds who are considering allowing medical marijuana business in their community. Sounds like it will cost about $5,000 per license upwards of 25-50 applications allowed. Do we need to report the activity in a SAR that the municipality is accepting applications?
04/01/2018
Can a child withdraw funds from an UTMA savings account if they have the okay from the parent that is the custodian on the account?
04/01/2018
123 LLC is owned by 2 individuals both at 33.33% and ABC, LLC which owns 33.34%. The natural individuals of ABC, LLC are John and Jane Doe. Would John and Jane Doe, in fact, be 16.67% owners of 123, LLC? This question is in regard's to the Certificate of Beneficial Ownership form.
03/25/2018
An Irrevocable trust - act separately or act together? The trust agreement doesn't state the powers the trustees have and how they should act upon it. The only thing it lists are the trustees that are joined with an "and." The trust is mainly about the property not financial accounts. The trustees would like the account setup so they can act separately, but I can't find any information on this. What are your thoughts?
03/25/2018
Can the Trustee of a formal trust account designate an authorized signer for the checking account?
03/25/2018
Is it a requirement to add/update our USA PATRIOT Act notice at CSR desks and disclosures for the CDD/Beneficial Ownership requirements, at account opening?
03/25/2018
We are a core processor for several banks. One of our banks has a rate on a time deposit that goes out to three decimal points 2.345. We show that rate in our online system the bank sees, but when we do the calculation and render the statement it shows as 2.35 on the statement to the customer. The customer wants to see the full rate on the statement. Is there any requirement addressing the number of decimal places for a rate on a statement?