We still keep a Monetary Instrument Log because it makes sense to us. If a customer that has a Phase 1 exemption for CTR reporting purposes purchases a money order in excess of $3,000, do we need to collect identifying on him or can we just note that the money order was purchased by a Phase 1 customer?

We still maintain the log also. However, branch personnel only complete the address, ss#, date of birth, ID section for NON-customers. For customers, we should have such info on file or at least have previously checked it.

An exemption from CTR reporting does not exempt the customer from anything else. Under the "old rules" (prior to the Regulatory Relief Act of 1996 - I think), you had to keep a log and you would have had to in this situation. Since 1996, no log is required, but all of the info is still required to be maintained. You must have all of the info somewhere (log or not). To record that they are a Phase I Exempt customer is not adequate.