Have an auditor that is suggesting that all of our Property Managers of HOAs are considered Third Party Payment Processors.
They state this because they accept payments on behalf of the HOA owner and they "establish deposit accounts to process the transactions" (see FIL-127-2008).
I do not believe an HOA is a "merchant" & I definitely don't feel a Property Manager is a TPPP - but is there any specific language anywhere I can direct the auditor to - to slam dunk that they don't apply?
This is the strangest interpretation I've ever heard ...