We have a customer who withdrew money at a branch and additional money at a non-proprietary ATM. How do we reflect the non-proprietary ATM in the transaction location section?

I had a similar situation and contacted FinCEN who told me how to file and what information is needed for the non proprietary ATM location. My advice would be to contact them, the representative told me also after our discussion to create a memo with his instructions to keep with the CTR in case there are questions from auditors / regulators.

Yes, I contacted them as well. It's an ATM owned by PNC so we will need to document that information. Still learning new things after all these years.