We have a customer who owns three medical billing businesses. I'm trying to figure out if they would be considered a TPPP? They accept payments on behalf of medical offices.

Not sure how they are not?

Nonbank or third-party payment processors (processors) are bank customers that provide payment-processing services to merchants and other business entities.

So, would a collection agency be considered a TPPP? We have one as a customer and we actually use them ourselves to collect on charged off accounts. They accept the payment and funnel a portion of it back to us (they keep their cut for collecting the payment).

Classic example - yes.