Bank customer receives ACH credits from it's third party clients to process payroll. However, bank customer does not initiate ACH debits to actually pay the payroll. They do, however, receive ACH debits from Intuit who processes/pays the payroll. NOTE - the ACH debit is initiated from Chase by Intuit and not the Bank's customer.

Is the Bank's customer a TPPP?

Thanks.

Over 115 views and no opinions - bumping to see why?

FWIW - OCC stated that they DO believe it meets the definition of a TPPP.

Yes they are. They receive payments from a third party that are not payments to them for services which they pass on to another third party.

Thanks!