We have a customer who came in with $10,500 in cash. Purchases three MI for $3500 each payable to three seperate individuals.

My first thought, each MI is between $3000 - $10000; therefore, each should be placed on the MI log; and file the CTR.

However, my second thought, is to aggregate the three MI and NOT place on the log and file the CTR.

Our new system we are testing acts like my second thought - our current system acts like my first thought.....

thoughts anyone???? (and thank you)

CTR trumps MIL since the CTR also records the MI purchases. That's my opinion.

Put it on both the CTR and the MIL

Why?? Since the cash involved was greater than $10,000, it falls outside of the MIL recordkeeping requirements.

The record keeping rule at 31 CFR 1010.415 is not applicable, since the cash transaction amount exceeds $10,000. You can certainly add it to an MI cash purchase record that you maintain for your own purposes, if you wish.

Thanks for all the responses.

Have a great week -