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Monetary Instrument Sales Form and Log

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If we adopt the overall bank policy that we will no longer sell monetary instruments to non-customers, and in addition require our customers to deposit cash into their accounts and then debit their accounts for official check purchases, will we still have to keep the Monetary Instrument Sales Form and Log? Can we adopt this policy and pass our examinations?

According to a November 2002 FinCEN interpretation letter, when a customer purchases a monetary instrument between $3,000 and $10,000 using currency that the customer first deposits into the customer’s account, the transaction is still subject to the record keeping requirements of Section 103.29. Section 103.29 does not require a log, but it does require you to keep all of the info (you might as well keep a log) in the situations you describe (customer first depositing cash then purchasing the official check).

First published on 2/05/07

First published on 02/05/2007

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