Affiliated Service Group Determination

Trying to determine if a potential new client is an Affiliated Service Group.  I don't think it is, but I wanted to be 100% sure:

Client is a management company, working with 40+ different affiliates.  While they have an ownership stake in each one, it is far less than the requirement to be a Controlled Group, and each individual affiliate has a different owner.

They perform management functions for each one, but obviously with more than 40, no one affiliate represents at least 50% of their functions (nor does it satisfy the receipt test)

From the way I'm looking at it, it wouldn't be considered an Affiliated Service Group but I wanted to be 100% sure.  Thanks in advance!