We had a customer that requested an IRA Distribution. We completed the distribution and made a cashier's check payable to the customer. The customer then ended up cashing the cashier's check which required a CTR. Should we consider this a negotiable instrument cashed with the cashier's check account number listed or a withdrawal and put the IRA account number? Thank you.

I would list it as a negotiable instrument cashed because they got a check and endorsed it and then cashed it.

I would list it as a withdrawal from the IRA account number. Your procedures may have required them to do it through a cashier's check, but his intent was to take cash from the IRA. This seems analogous to question 30 in the CTR FAQs.

https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr