We have a community college that has the following procedures when it comes to student loans and pell grants. If a student has applied for a student loan or a pell grant the school has the check made payable to the student AND the school. When the student receives the check he/she will go to the school and endorse the check and the school will apply the tuition and other fees the student may owe and gives the student the remainder in cash. A school representative will come to the bank and cash the checks and take cash out of the bank. If the transaction is more than $10,000 a CTR is filed. The bank has a letter from the school that authorizes them to do this. These checks never hit the school's account, so if I did not know about this then it would not be detected.
My question is (1) Should they be considered as a MSB since I know some checks may be between 3,000 and 6,000. I looked for this in reg and could not find anything on this. (2) I am considering granting them as an exempt customer. Your opinions.