BSA - Is Savings Bond a Monetary Instrument?

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Question:

Husband and wife customers came in and purchased $10,000 in savings bonds. They used a $4,000 on us check and a $3,000 savings withdrawal and $3,000 in cash. Our bank completes Monetary Instrument Logs for Official Checks, Travelers Checks, and Cashier’s Checks that are purchased with cash between $3,000-$10,000. Would a Savings Bond qualify as a "Monetary Instrument"?

Answer:

No. The recordkeeping requirement to which you refer doesn't require a log in any event, but many banks use a log format because of the ease of use. However, the contents of the required records includes purchases with cash in amounts of $3,000 to $10,000 inclusive of "bank checks and drafts, cashier's checks, money orders and traveler's checks."

It would be inappropriate to include records of other types of cash purchases -- savings bonds, stored value for example -- in that log. It would not be inappropriate to have a second log in which such records are maintained, if the bank felt it needed it in order to better monitor for suspicious activity or aggregate cash activity for CTR purposes.

First published on BankersOnline.com 5/18/09