The New York Division of Tax Appeals determined that an online loan marketplace was not a taxable information service. The taxpayer operates an online loan marketplace where it connects and matches prospective borrowers seeking loans (and other credit-based products) with lenders that are seeking qualified borrowers. The taxpayer generated revenue through agreements with each lender upfront matching fees and/or closed loan fees. The Department assessed the taxpayer for sales tax, asserting that its receipts were taxable information service, which requires the primary function be the business of furnishing information, including collecting, compiling, or analyzing information. The ALJ determined that the taxpayer’s primary function was not a taxable information service, but the facilitation of its customers writing loans to prospective borrowers. The ALJ concluded that the primary function of the service, and not the means of effectuating the service, determine its taxability as an information service.