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Hopefully this excerpt from the Interagency Guidance answers your question:
"A third-party relationship may exist despite a lack of a contract or remuneration. Third-party relationships can include, but are not limited to, outsourced services, use of independent consultants, referral arrangements, merchant payment processing services, services provided by affiliates and subsidiaries, and joint ventures." (page 30)
Original Message:
Sent: 11-13-2023 01:40 PM
From: Anonymous Member
Subject: Signature guarantee/Medallion STAMP
This message was posted by a user wishing to remain anonymous
Do you classify this type of service provider as a "vendor"? I am getting conflicting information on whether they should/would be considered a vendor.