CTR required ?

Scenario - Mr. Customer visits bank with cash and purchases several checks payable to an exempt customer exceeding the CTR limit.
CTR required? I'm leaning towards yes as Mr. Customer is not exempt and he is the one who brought in the cash.
Thoughts?

Yes Mr. Customer is not exempt and he is the one who brought in the cash

Mr. Customer is not a messenger for the exempt?

The again why would it be several checks?

SAR investigation?

Does it matter if its a Phase1 or a Phase2 Exempt customer?

Phase I customers are exempt for all large currency transactions. Phase II customers are only exempt for deposits and withdrawals.

That's irrelevant here because the individual, not the customer, was the purchaser. (The customer was the payee on the checks, not the remitter.)

Just to put an unrequested bow on this, if the scenario were a bit different and the remitter were an exempt government agency, and the total of the purchase transaction were $9,500, don't get confused and forget to make your cash purchases of monetary instruments recordkeeping entry. There are no exemptions from that requirement, and the purchaser in such a case would be the individual making the purchase, not the remitter.