Recordkeeping for Indirect Monetary Instruments Purchases

Question - I understand that credit unions must record certain information when a member purchases monetary instruments in amounts between $3,000 and $10,000.  My credit union, however, does not allow its members to purchase money orders and traveler's checks directly with cash. We require members first to deposit the cash into their credit union account. We then perform an internal transfer to purchase the monetary instruments. Do we still need to comply with the recordkeeping requirements?