I frequently (every week or so) go to an ATM that is in a bank that I do not have an account in. I withdraw $500 and the machine dispenses $20 bills. I then walk up to the teller and exchange the bills for smaller denominations. Today I was asked for my ID and that they needed it for potentially filing a currency transaction report. Ignoring the fact that $500 is way less than the $10,000 reporting requirements1, would this type of transaction ever require a CTR? The guidance makes it clear that changing currencies (e.g., Euros to USD) is a transaction that needs to be reported. Is asking a bank to exchange USD bills in one denomination to USD bills in a different denomination considered a transaction?
1 Potentially they were worried that I might be conducting lots of small transactions, although I would think that if I keep circling through the line they would eventually ask me to stop since I am not an account holder at their bank.