Since they make a withdrawal, and then wire, there is no third party, just the bank and the customer. It is an OTC transaction and would be excluded. If they requested it as an automatic debit and wire each month the answer would be different.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell