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No Accounts, but Customers for CIP Purposes?

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Question: 
We have a payment processor who has a relationship with an ISO who procures new merchant relationships for them. The merchants do not have accounts with us, but because we process their ach transactions through our payment processor, does that make them our customer as far as CIP?
Answer: 

No.

First published on BankersOnline.com 11/16/09

First published on 11/16/2009

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