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#2259086 - 09/01/21 02:22 PM Monetary Instrument Log
Jennifer Offline
100 Club
Joined: Dec 2014
Posts: 176
Customer brings in $3,000 to purchase a cashiers check; however check is issued for $2,980 ($20 cash out). Is a log still required to be completed?

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#2259088 - 09/01/21 02:31 PM Re: Monetary Instrument Log Jennifer
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
The recordkeeping requirement is triggered by the amount of cash involved in the transaction. Here is the intro text of 31 CFR 1010.415(a):
"No financial institution may issue or sell a bank check or draft, cashier's check, money order or traveler's check for $3,000 or more in currency unless it maintains records of the following information, which must be obtained for each issuance or sale of one or more of these instruments to any individual purchaser which involves currency in amounts of $3,000–$10,000 inclusive:"

I admit that the way FinCEN words this makes the answer to your question a little fuzzy (the check is not for $3,000 or more), but I recommend conservative compliance here. You'll never get cited for including it in your records. But if your examiner says it should have been there and you left it out on this technicality, you could be cited. This is a case of "Better safe than sorry."
Last edited by John Burnett; 09/01/21 03:33 PM. Reason: added thought.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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