At my bank, we require all negotiable instruments to be purchased with a debit from their account. We do not sell negotiable instruments to non-customers. We recently had a BSA audit that stated that even if our customer deposited the cash into their account, we should still be logging those on our negotiable instrument log ($3K-$10K) because even though technically the payment was made by a debit from their account, the customer's intent was to pay for it with cash.
Does this sound right to anyone else?
We're thinking about changing our process where we no longer require the customer to deposit the cash into their bank account and just pay for the negotiable instrument with cash. This makes my radar go off but I don't know if it's because that doesn't sound right or if it's because it's changing the way we've done it for 20+ years.
Any help/guidance is appreciated.