I'm not sure that is correct in this case. It appears Netspend was interacting with their own customer in the context of one of it's own processes. They weren'

I'm not sure that is correct in this case. It appears Netspend was interacting with their own customer in the context of one of it's own processes. They weren't doing so as a TPV working on behalf of the banking institution that the customer would be using Netspend to transfer money from/to. -Example- Netspend: Thanks for signing up for Netspend. We need to verifying your real. Please go to netspend.com/validate and provide y. If Netspend was asking or directing the customer to provide information on, or interact with the banking institutions own properties then yes, I can see how you'd be correct. -Example- Netspend: You've indicated you use Example Bank. In order for us to link to your EB account please go to example.com/myaccount and do x, y, and z.