The exemption is for the customer, and covers all of that customer's exemptible accounts. You should include all of the customer's transaction, MMDA, and savings accounts that permit third party activity. Do not include accounts for which the customer is acting on behalf of a third party (such as a lottery account, or an account of a grocery store on behalf of various utility companies for which it accepts payments).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8