Answer:
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 BankersOnline.com 2/05/07