Our tellers continue to use their cash transaction logs to record the cash sales ($3,000 & over) of monetary instruments. I always check their logs against a currency transaction report that is generated daily. Yesterday, I noticed one of our branches had sold a cashier's check in the amount of $6,100 cash and had not listed the sale. The branch managers reasoning was that this was one of our Phase I exempt customers and therefore they did not have to record the transaction. I argue that it does need to be listed, mostly due to the fact that in our recent FRB examination, the cash transaction logs and currency transaction reports were gone over with a fine tooth comb to make certain that we had recorded all monetary instrument sales $3,000 cash & over. Does exempt status also mean exemption from monetary instrument sales documentation?

No. Not exempt at all. All sales should be recorded. Usually an exemption is for Deposits or withdrawal from an account. not for purchasing monetary instruments.

Thanks, that's what I thought and I ask her to comply. Just wanted to make sure I knew what I was talking about.