BSA question for Credit Union world:

A CU hosts a share branch, and a member from another credit union comes in to purchase a monetary instrument, but does so by authorizing a withdrawal from their home CU account.

Technically, this is not a purchase in currency - so would this transaction not require the Monetary Instrument record-keeping?

The share-branch member is not a member of the credit union hosting the branch, so it's a non-member purchase, but again, no currency.

No. If actual cash was not brought in to the branch to make the purchase, then it would not trigger the MIL. HOWEVER, because it will look like a cash withdrawal and a cash purchase, I would document it. I would make a copy of the receipts with a quick note that no cash was brought into the branch, that the funds were pulled from a CUSC account and used to make the purchase.
I do this for CTRs. Any time a member "transfers" money over $10,000 from our CU to another, or vice versa, I just make copies of the receipts and keep it with my CTR report.
Hope this helps!
-K

Thanks! Share branching definately puts a unique twist on BSA - especially since the MIS for share branch systems looks like it belongs in 1992.