Our examiners told us that for CTR activity, we should always look at the source of the funds.
So if our system requires that the check be deposited first and then cash w/d, then we list it as a negotiable item that was cashed.
In this particular transaction, the customer obtained a loan. The loan funds were advanced to his checking. He made the w/d from his checking. The checking account number ties the actual cash out to the transaction. But, according to the examiners, we need to indicate that this was (b)-- credit advancement. There is no way to fully link the transactions without listing the loan and the checking account, but then it looks like it was multiple transactions. And while that is true, these were not multiple cash transactions, so we wouldn't select multiple cash transactions.
How do I fill this out correctly?