what box do we check on the ctr if a customer brings in over $10k in cash to pay directly on a loan. Box 34 looks like it only applys to deposti accounts - is there a box we can check that applies to a loan?

I would mark the box 34 and put the loan number for the account number. In the instructions for 34 it states for DDA, SAV and any other account held at the institution which I would take to be a loan as well.

That practice would probably pass muster, although I prefer to think of "account" in item 34 as "deposit account," particularly because the instructions for item 34 mention "deposits to" the account. I would check "other" and insert "loan payment" on one of the lines below it.

Whether I use item 34 or item 36, I'd also check item 35 and include the account number.

And something odd about e-filed CTRs...If you check 36 (other) you can't enter an account number in field 35 because field 35 is unselectable.

#31 (Negotiable Instrument Purchased) should be marked for loan payments. Then list the loan account # in #35.

I must disagree with David. The customer is not buying a negotiable instrument. He is paying a loan. David and I have discussed this question before, and I am aware of his stance, but I don't agree with it, and I have not seen anything remotely approaching official on the question.

John --
How then do you reconcile 31 CFR 103.11(u) that defines a promissory note as a negotiable instrument as defined in the Uniform Commercial Code (assuming that reference is to Section 9.102 of the UCC)?

Smash,

You did not read the rest of the definition. It says:
"that are either in bearer form, endorsed without restriction, made out to a fictitious payee (for the purposes of §103.23), or otherwise in such form that title thereto passes upon delivery". How many ordinary bank loans do you know of that fit that category?

I agree with John. A loan payment is exactly that. It is a payment and not the purchase of anything.