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{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-099","record":{"id":"src-099","title":"Company statement source · src-099","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"company_statement","publisher_type":"nonprofit"},"reading":"Company statement source · src-099"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-100","record":{"id":"src-100","title":"Other source · src-100","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"other","publisher_type":"corporate"},"reading":"Other source · src-100"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-101","record":{"id":"src-101","title":"Evolve Bank & Trust 2022 annual report (Business ID 956221)","url":"https://corp.sos.ms.gov/corpconv/portal/c/ExecuteWorkflow.aspx?workflowid=g12dbd558-fa5d-49a1-a869-ad8b9db198db&FilingId=9e9314ed-838f-41bf-8f8b-fb087c966712","publisher":"Mississippi Secretary of State","date":"2022-04-10","locator":"Annual report","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"corporate_registry","publisher_type":"registry_operator"},"reading":"Evolve Bank & Trust 2022 annual report (Business ID 956221), Mississippi Secretary of State"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-102","record":{"id":"src-102","title":"BrokerCheck report: John Thomas Pitts Jr (CRD 2342184)","url":"https://files.brokercheck.finra.org/individual/individual_2342184.pdf","publisher":"FINRA BrokerCheck","date":"2026-10-16","locator":"Registration history and outside business activities","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"regulatory_record","publisher_type":"regulator"},"reading":"BrokerCheck report: John Thomas Pitts Jr (CRD 2342184), FINRA BrokerCheck"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-103","record":{"id":"src-103","title":"Media source · src-103","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-103"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-104","record":{"id":"src-104","title":"Media source · src-104","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-104"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-105","record":{"id":"src-105","title":"Raymond James Financial, Inc. list of subsidiaries (Exhibit 21, fiscal 2020)","url":"https://www.sec.gov/Archives/edgar/data/720005/000072000520000063/ex2120200930-10k.htm","publisher":"U.S. Securities and Exchange Commission (EDGAR)","date":"2020-11","locator":"Exhibit 21","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"company_statement","publisher_type":"regulator"},"reading":"Raymond James Financial, Inc. list of subsidiaries (Exhibit 21, fiscal 2020), U.S. Securities and Exchange Commission (EDGAR)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-106","record":{"id":"src-106","title":"Formations of, acquisitions by, and mergers of bank holding companies (June 25, 2004)","url":"https://www.federalregister.gov/documents/2004/06/25/04-14416/formations-of-acquisitions-by-and-mergers-of-bank-holding-companies","publisher":"Office of the Federal Register","date":"2004-06-25","locator":"SunTrust Banks notice","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"regulatory_record","publisher_type":"government"},"reading":"Formations of, acquisitions by, and mergers of bank holding companies (June 25, 2004), Office of the Federal Register"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-107","record":{"id":"src-107","title":"Buckeye Technologies Inc. Form 10-K for the fiscal year ended June 30, 2013","url":"https://www.sec.gov/Archives/edgar/data/899597/000119312513352169/d589842d10k.htm","publisher":"U.S. Securities and Exchange Commission (EDGAR)","date":"2013-08","locator":"Directors and executive officers","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"company_statement","publisher_type":"regulator"},"reading":"Buckeye Technologies Inc. Form 10-K for the fiscal year ended June 30, 2013, U.S. Securities and Exchange Commission (EDGAR)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-108","record":{"id":"src-108","title":"Report of the Bank Commissioner of the State of Arkansas 2023","url":"https://banking.arkansas.gov/wp-content/uploads/2025/07/ROBC2023.pdf","publisher":"Arkansas State Bank Department (Bank Commissioner)","date":"2025-07","locator":"Evolve Bank & Trust entry","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"regulatory_record","publisher_type":"regulator"},"reading":"Report of the Bank Commissioner of the State of Arkansas 2023, Arkansas State Bank Department (Bank Commissioner)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-109","record":{"id":"src-109","title":"Court record source · src-109","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"court_record","publisher_type":"nonprofit"},"reading":"Court record source · src-109"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-110","record":{"id":"src-110","title":"Media source · src-110","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-110"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-111","record":{"id":"src-111","title":"Media source · src-111","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-111"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-112","record":{"id":"src-112","title":"Media source · src-112","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-112"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-113","record":{"id":"src-113","title":"Court record source · src-113","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"court_record","publisher_type":"nonprofit"},"reading":"Court record source · src-113"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-114","record":{"id":"src-114","title":"Company statement source · src-114","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"company_statement","publisher_type":"corporate"},"reading":"Company statement source · src-114"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-115","record":{"id":"src-115","title":"Media source · src-115","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-115"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-116","record":{"id":"src-116","title":"Evolve Commercial Finance, Inc. 2023 foreign profit corporation annual report (F18000001198)","url":"https://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=forp-f18000001198-cd32ad1d-fea6-4e65-b3ce-84795dbc7d87&transactionId=f18000001198-fe50fd93-bab3-40f1-814a-1b5f3f76517d&formatType=PDF","publisher":"Florida Department of State, Division of Corporations","date":"2023-03-05","locator":"Annual report","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"corporate_registry","publisher_type":"registry_operator"},"reading":"Evolve Commercial Finance, Inc. 2023 foreign profit corporation annual report (F18000001198), Florida Department of State, Division of Corporations"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-117","record":{"id":"src-117","title":"FDIC financial data for Evolve Bank & Trust, December 31, 2025","url":"https://api.fdic.gov/banks/financials?filters=CERT%3A1299%20AND%20REPDTE%3A20251231&fields=CERT%2CREPDTE%2CASSET%2CDEP%2CNETINC%2CEQ%2CDEPUNINS%2CRBCT1J&format=json","publisher":"Federal Deposit Insurance Corporation","date":"2026-10-16","locator":"Call-report fields (JSON)","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"statistical_data","publisher_type":"regulator"},"reading":"FDIC financial data for Evolve Bank & Trust, December 31, 2025, Federal Deposit Insurance Corporation"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-118","record":{"id":"src-118","title":"FDIC financial data for Evolve Bank & Trust, 2019 to 2024","url":"https://api.fdic.gov/banks/financials?filters=CERT%3A1299%20AND%20REPDTE%3A%5B20191231%20TO%2020241231%5D&fields=CERT%2CREPDTE%2CASSET%2CDEP%2CNETINC%2CEQ&sort_by=REPDTE&sort_order=ASC&limit=30&format=json","publisher":"Federal Deposit Insurance Corporation","date":"2026-10-16","locator":"Call-report fields (JSON)","basis":"Retained copy of the document in the frozen case database, read in the passages cited by the claims.","accessed":"2026-10-16","source_type":"statistical_data","publisher_type":"regulator"},"reading":"FDIC financial data for Evolve Bank & Trust, 2019 to 2024, Federal Deposit Insurance Corporation"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"sources","id":"src-119","record":{"id":"src-119","title":"Media source · src-119","url":"","publisher":"","date":"","locator":"","basis":"Source classification retained; identifying metadata omitted.","accessed":"","source_type":"media","publisher_type":"media"},"reading":"Media source · src-119"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-fdic-record","record":{"id":"c-id-fdic-record","kind":"fact","text":"In the FDIC BankFind institution record retrieved on October 16, 2026, Evolve Bank & Trust is an active, FDIC-insured, Arkansas-chartered commercial bank in West Memphis, Arkansas, with FDIC Certificate No. 1299 and Federal Reserve RSSD ID 592448. The record gives its establishment date as June 5, 1925, deposit insurance from January 1, 1934, and a head office at 301 Shoppingway Blvd in Crittenden County.","source_ids":["src-001"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the FDIC BankFind institution record retrieved on October 16, 2026, Evolve Bank & Trust is an active, FDIC-insured, Arkansas-chartered commercial bank in West Memphis, Arkansas, with FDIC Certificate No. 1299 and Federal Reserve RSSD ID 592448. The record gives its establishment date as June 5, 1925, deposit insurance from January 1, 1934, and a head office at 301 Shoppingway Blvd in Crittenden County."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-fed-member","record":{"id":"c-id-fed-member","kind":"fact","text":"The FDIC record classifies Evolve Bank & Trust as a state-chartered bank that is a member of the Federal Reserve System (class SM) and names the Federal Reserve, in its eighth (St. Louis) district, as the bank's primary federal regulator. The record lists 10 domestic offices.","source_ids":["src-001"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The FDIC record classifies Evolve Bank & Trust as a state-chartered bank that is a member of the Federal Reserve System (class SM) and names the Federal Reserve, in its eighth (St. Louis) district, as the bank's primary federal regulator. The record lists 10 domestic offices."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-name-history","record":{"id":"c-id-name-history","kind":"fact","text":"The FDIC record gives the bank's prior name as First State Bank. The bank's own timeline states that it opened in June 1925 as First State Bank, the primary financial institution in eastern Cross County, Arkansas, and that in 2005 it changed its name to Evolve Bank & Trust and added trust powers.","source_ids":["src-001","src-005"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The FDIC record gives the bank's prior name as First State Bank. The bank's own timeline states that it opened in June 1925 as First State Bank, the primary financial institution in eastern Cross County, Arkansas, and that in 2005 it changed its name to Evolve Bank & Trust and added trust powers."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-state-charter","record":{"id":"c-id-state-charter","kind":"fact","text":"The Arkansas State Bank Department's annual report with data as of June 30, 2025 lists Evolve Bank & Trust of West Memphis under state charter number 568, dated June 5, 1925, with trust powers, FDIC Certificate Number 1299, membership of the Federal Reserve System and Evolve Bancorp, Inc. of West Memphis as its bank holding company.","source_ids":["src-024"],"entity_ids":["evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Arkansas State Bank Department's annual report with data as of June 30, 2025 lists Evolve Bank & Trust of West Memphis under state charter number 568, dated June 5, 1925, with trust powers, FDIC Certificate Number 1299, membership of the Federal Reserve System and Evolve Bancorp, Inc. of West Memphis as its bank holding company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-memphis-offices","record":{"id":"c-id-memphis-offices","kind":"fact","text":"Although the charter and head office are in West Memphis, Arkansas, the bank's executives work from Memphis, Tennessee. The Federal Reserve's June 2024 order was addressed to the bank's chief executive at Triad Centre 1, 6000 Poplar Avenue, Suite 300, Memphis, Tennessee 38119; a 2021 bank press release gave its office as 6070 Poplar Avenue, Suite 200, Memphis.","source_ids":["src-003","src-007"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Although the charter and head office are in West Memphis, Arkansas, the bank's executives work from Memphis, Tennessee. The Federal Reserve's June 2024 order was addressed to the bank's chief executive at Triad Centre 1, 6000 Poplar Avenue, Suite 300, Memphis, Tennessee 38119; a 2021 bank press release gave its office as 6070 Poplar Avenue, Suite 200, Memphis."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-mississippi","record":{"id":"c-id-mississippi","kind":"fact","text":"Evolve Bank & Trust is registered with the Mississippi Secretary of State as a corporation incorporated in Arkansas (Business ID 956221). Its 2022 annual report, filed on April 10, 2022, gives a principal address at 6070 Poplar Ave, Suite 200, Memphis, names Corporation Service Company in Madison, Mississippi as registered agent, describes the business as commercial banking (NAICS 522110) and reports 4,000 common shares authorized and issued, without naming the holder.","source_ids":["src-101"],"entity_ids":["evolve","corporation-service-company"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve Bank & Trust is registered with the Mississippi Secretary of State as a corporation incorporated in Arkansas (Business ID 956221). Its 2022 annual report, filed on April 10, 2022, gives a principal address at 6070 Poplar Ave, Suite 200, Memphis, names Corporation Service Company in Madison, Mississippi as registered agent, describes the business as commercial banking (NAICS 522110) and reports 4,000 common shares authorized and issued, without naming the holder."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-lei","record":{"id":"c-id-lei","kind":"attributed","text":"A commercial screening record compiled from GLEIF, Federal Reserve enforcement and commercial company data matches Evolve Bank & Trust by registration number 1299 and lists legal entity identifier (LEI) 549300IRXW9RSZM2B951.","source_ids":["src-009","src-001"],"entity_ids":["evolve"],"qualification":"The LEI comes from a third-party compilation of GLEIF data; no GLEIF record is among the retained documents, and the LEI field of the FDIC institution record is blank.","response":"","outcome":""},"reading":"Attributed: A commercial screening record compiled from GLEIF, Federal Reserve enforcement and commercial company data matches Evolve Bank & Trust by registration number 1299 and lists legal entity identifier (LEI) 549300IRXW9RSZM2B951."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-id-screening","record":{"id":"c-id-screening","kind":"fact","text":"The same screening record tags Evolve Bank & Trust with the topics 'corp.public', 'reg.action' and 'fin.bank' under the Federal Reserve enforcement programme, citing the Board's enforcement releases of June 21, 2022 and June 14, 2024; a separate record for Evolve Bancorp, Inc. carries 'reg.action' and 'fin.bank' and cites the June 14, 2024 release. Neither record carries a sanctions topic.","source_ids":["src-009","src-010"],"entity_ids":["evolve","evolve-bancorp"],"qualification":"These are third-party screening tags derived from published enforcement releases, not a fresh sanctions screening.","response":"","outcome":""},"reading":"Fact: The same screening record tags Evolve Bank & Trust with the topics 'corp.public', 'reg.action' and 'fin.bank' under the Federal Reserve enforcement programme, citing the Board's enforcement releases of June 21, 2022 and June 14, 2024; a separate record for Evolve Bancorp, Inc. carries 'reg.action' and 'fin.bank' and cites the June 14, 2024 release. Neither record carries a sanctions topic."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-fdic-holding","record":{"id":"c-grp-fdic-holding","kind":"fact","text":"The FDIC record names EVOLVE BCORP INC (Evolve Bancorp, Inc.), RSSD 1142411 of West Memphis, Arkansas, as the bank's regulatory holding company.","source_ids":["src-001"],"entity_ids":["evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: The FDIC record names EVOLVE BCORP INC (Evolve Bancorp, Inc.), RSSD 1142411 of West Memphis, Arkansas, as the bank's regulatory holding company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-fed-list","record":{"id":"c-grp-fed-list","kind":"fact","text":"The Federal Reserve's list of holding companies shows RSSD 1142411 as Evolve Bancorp, Inc. of West Memphis, a bank holding company since February 10, 1987, and the same RSSD under the earlier name Parkin Bancorp, Inc. of Parkin, Arkansas, for February 10, 1987 to December 31, 2006. The list records Evolve Financial Group, Inc. of Memphis (RSSD 3343351) as a bank holding company from August 1, 2005 to December 30, 2013.","source_ids":["src-013"],"entity_ids":["evolve-bancorp","evolve-financial-group"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Federal Reserve's list of holding companies shows RSSD 1142411 as Evolve Bancorp, Inc. of West Memphis, a bank holding company since February 10, 1987, and the same RSSD under the earlier name Parkin Bancorp, Inc. of Parkin, Arkansas, for February 10, 1987 to December 31, 2006. The list records Evolve Financial Group, Inc. of Memphis (RSSD 3343351) as a bank holding company from August 1, 2005 to December 30, 2013."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-2005-purchase","record":{"id":"c-grp-2005-purchase","kind":"fact","text":"On June 20, 2005, a regional business publication reported that Evolve Financial Group of Memphis, a financial services venture formed in January 2004 and organized by B. Scot Lenoir, was seeking to buy Parkin Bancorp Inc., the holding company of First State Bank of Parkin (which also had a West Memphis branch and reported total assets of nearly $22 million at March 31, 2005); the proposed acquisition was under regulatory review.","source_ids":["src-033"],"entity_ids":["evolve-financial-group","evolve-bancorp","scot-lenoir","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: On June 20, 2005, a regional business publication reported that Evolve Financial Group of Memphis, a financial services venture formed in January 2004 and organized by B. Scot Lenoir, was seeking to buy Parkin Bancorp Inc., the holding company of First State Bank of Parkin (which also had a West Memphis branch and reported total assets of nearly $22 million at March 31, 2005); the proposed acquisition was under regulatory review."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-2006-structure","record":{"id":"c-grp-2006-structure","kind":"fact","text":"The Arkansas Bank Commissioner's report with data as of June 30, 2006 shows a two-tier structure. Evolve Financial Group, Inc. of Memphis (RSSD 3343351), with Scot Lenoir as chairman and chief executive and Scott Stafford as secretary, listed as subsidiaries Parkin Bancorp, Inc., Evolve Bank & Trust, Evolve Advisors, Inc., Evolve Benefits Group, Inc., Evolve Financial Services, Inc., Evolve Mortgage Services, Inc. and Evolve Securities, Inc. Parkin Bancorp, Inc. (RSSD 1142411), with the same chairman and secretary, named Evolve Financial Group as its bank holding company and Evolve Bank & Trust, then based in Parkin, as its subsidiary.","source_ids":["src-025"],"entity_ids":["evolve-financial-group","evolve-bancorp","evolve","evolve-advisors","evolve-benefits-group","evolve-financial-services","evolve-mortgage-services","evolve-securities","scot-lenoir","scott-stafford"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Arkansas Bank Commissioner's report with data as of June 30, 2006 shows a two-tier structure. Evolve Financial Group, Inc. of Memphis (RSSD 3343351), with Scot Lenoir as chairman and chief executive and Scott Stafford as secretary, listed as subsidiaries Parkin Bancorp, Inc., Evolve Bank & Trust, Evolve Advisors, Inc., Evolve Benefits Group, Inc., Evolve Financial Services, Inc., Evolve Mortgage Services, Inc. and Evolve Securities, Inc. Parkin Bancorp, Inc. (RSSD 1142411), with the same chairman and secretary, named Evolve Financial Group as its bank holding company and Evolve Bank & Trust, then based in Parkin, as its subsidiary."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-2015","record":{"id":"c-grp-2015","kind":"fact","text":"In the Arkansas Bank Commissioner's report with data as of June 30, 2015, Evolve Bancorp, Inc. (RSSD 1142411, West Memphis) is a bank holding company with Scot Lenoir as chairman, Scott Stafford as secretary and Evolve Bank & Trust as its only listed subsidiary.","source_ids":["src-070"],"entity_ids":["evolve-bancorp","evolve","scot-lenoir","scott-stafford"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the Arkansas Bank Commissioner's report with data as of June 30, 2015, Evolve Bancorp, Inc. (RSSD 1142411, West Memphis) is a bank holding company with Scot Lenoir as chairman, Scott Stafford as secretary and Evolve Bank & Trust as its only listed subsidiary."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-2024","record":{"id":"c-grp-2024","kind":"fact","text":"In the report with data as of June 30, 2024, Evolve Bancorp, Inc. lists B. Scot Lenoir as chairman, Scott Stafford as secretary and Robin Bedsole as controller, and two subsidiaries: Evolve Bank & Trust of West Memphis and Evolve Commercial Finance of Memphis, Tennessee.","source_ids":["src-039"],"entity_ids":["evolve-bancorp","evolve","evolve-commercial-finance","scot-lenoir","scott-stafford","robin-bedsole"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the report with data as of June 30, 2024, Evolve Bancorp, Inc. lists B. Scot Lenoir as chairman, Scott Stafford as secretary and Robin Bedsole as controller, and two subsidiaries: Evolve Bank & Trust of West Memphis and Evolve Commercial Finance of Memphis, Tennessee."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-2025","record":{"id":"c-grp-2025","kind":"fact","text":"In the report with data as of June 30, 2025, Evolve Bancorp, Inc. lists Stephen Valentine as chairman, Alvinor Bright, Jr. as vice chairman and Mark Mosteller as chief financial officer, with the same two subsidiaries, Evolve Bank & Trust and Evolve Commercial Finance.","source_ids":["src-024"],"entity_ids":["evolve-bancorp","evolve","evolve-commercial-finance","steve-valentine","al-bright","mark-mosteller"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the report with data as of June 30, 2025, Evolve Bancorp, Inc. lists Stephen Valentine as chairman, Alvinor Bright, Jr. as vice chairman and Mark Mosteller as chief financial officer, with the same two subsidiaries, Evolve Bank & Trust and Evolve Commercial Finance."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-ecf-florida","record":{"id":"c-grp-ecf-florida","kind":"fact","text":"Evolve Commercial Finance, Inc. filed a 2023 annual report as a foreign profit corporation with the Florida Division of Corporations (document F18000001198, filed March 5, 2023; FEI number 81-3742575). It gives 6000 Poplar Ave, Triad I Suite 300, Memphis as its principal address and lists W. Scott Stafford as president, B. Scot Lenoir as director, Mark Mosteller as treasurer and Henry A. Barham III as secretary; Barham signed the report. Corporation Service Company was its registered agent in Tallahassee.","source_ids":["src-116"],"entity_ids":["evolve-commercial-finance","scott-stafford","scot-lenoir","mark-mosteller","henry-barham","corporation-service-company"],"qualification":"The filing spells the street 'Popular Ave'.","response":"","outcome":""},"reading":"Fact: Evolve Commercial Finance, Inc. filed a 2023 annual report as a foreign profit corporation with the Florida Division of Corporations (document F18000001198, filed March 5, 2023; FEI number 81-3742575). It gives 6000 Poplar Ave, Triad I Suite 300, Memphis as its principal address and lists W. Scott Stafford as president, B. Scot Lenoir as director, Mark Mosteller as treasurer and Henry A. Barham III as secretary; Barham signed the report. Corporation Service Company was its registered agent in Tallahassee."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-shares-2022","record":{"id":"c-grp-shares-2022","kind":"fact","text":"Evolve Bancorp's consolidated balance sheet at March 31, 2022 (unaudited), published with its first-quarter 2022 shareholder letter, reports total assets of $777,650,740, $40,000,000 of Federal Home Loan Bank advances, $31,100,468 of subordinated debt, Class A preferred stock of $3,377,475, 4,646,210 common shares outstanding (4,554,460 at the end of 2021) and total shareholders' equity of $65,315,265.","source_ids":["src-034"],"entity_ids":["evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve Bancorp's consolidated balance sheet at March 31, 2022 (unaudited), published with its first-quarter 2022 shareholder letter, reports total assets of $777,650,740, $40,000,000 of Federal Home Loan Bank advances, $31,100,468 of subordinated debt, Class A preferred stock of $3,377,475, 4,646,210 common shares outstanding (4,554,460 at the end of 2021) and total shareholders' equity of $65,315,265."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-sblf","record":{"id":"c-grp-sblf","kind":"fact","text":"The U.S. Treasury's July 2014 report on the Small Business Lending Fund (data as of March 31, 2014) lists Evolve Bancorp, Inc. of Cordova, Tennessee, with $4,699,000 of SBLF funding outstanding, small-business lending of $87,004,000 against a baseline of $19,101,000 (an increase of 355.49%) and a 1.00% dividend rate.","source_ids":["src-040"],"entity_ids":["evolve-bancorp","us-treasury"],"qualification":"","response":"","outcome":""},"reading":"Fact: The U.S. Treasury's July 2014 report on the Small Business Lending Fund (data as of March 31, 2014) lists Evolve Bancorp, Inc. of Cordova, Tennessee, with $4,699,000 of SBLF funding outstanding, small-business lending of $87,004,000 against a baseline of $19,101,000 (an increase of 355.49%) and a 1.00% dividend rate."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-minor-holder","record":{"id":"c-grp-minor-holder","kind":"fact","text":"In his FINRA BrokerCheck disclosure of outside activities, director Donald B. Clanton reported being a board member and minor stockholder of Evolve Bank & Trust since 2005.","source_ids":["src-023"],"entity_ids":["donald-clanton","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: In his FINRA BrokerCheck disclosure of outside activities, director Donald B. Clanton reported being a board member and minor stockholder of Evolve Bank & Trust since 2005."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-grp-owners-unknown","record":{"id":"c-grp-owners-unknown","kind":"unresolved","text":"The retained record does not identify Evolve Bancorp's principal shareholders. Requests to the Federal Reserve's National Information Center for the holding company's FR Y-6 annual reports dated December 31, 2024 and December 31, 2025 returned an error page, and the retained copy of its parent-company-only FR Y-9SP report for December 31, 2025 contains the blank form without values.","source_ids":["src-002","src-017","src-018"],"entity_ids":["evolve-bancorp"],"qualification":"An error page shows only that the filings could not be retrieved at that time; it does not mean the reports were not filed or cannot be obtained from the Federal Reserve.","response":"","outcome":""},"reading":"Unresolved: The retained record does not identify Evolve Bancorp's principal shareholders. Requests to the Federal Reserve's National Information Center for the holding company's FR Y-6 annual reports dated December 31, 2024 and December 31, 2025 returned an error page, and the retained copy of its parent-company-only FR Y-9SP report for December 31, 2025 contains the blank form without values."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-2006","record":{"id":"c-brd-2006","kind":"fact","text":"The Arkansas Bank Commissioner's report with data as of June 30, 2006 lists Evolve Bank & Trust, then of Parkin, with Scot Lenoir as chairman, John Cooper as president, Scott Stafford as chief executive and Kenneth Lenoir as executive vice president, and with directors Donald Clanton, John Cooper, J. De DeHart, Scot Lenoir, Victor Saig, Scott Stafford and Stephen Valentine.","source_ids":["src-025"],"entity_ids":["evolve","scot-lenoir","john-cooper","scott-stafford","kenneth-lenoir","donald-clanton","j-de-dehart","victor-saig","steve-valentine"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Arkansas Bank Commissioner's report with data as of June 30, 2006 lists Evolve Bank & Trust, then of Parkin, with Scot Lenoir as chairman, John Cooper as president, Scott Stafford as chief executive and Kenneth Lenoir as executive vice president, and with directors Donald Clanton, John Cooper, J. De DeHart, Scot Lenoir, Victor Saig, Scott Stafford and Stephen Valentine."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-2015","record":{"id":"c-brd-2015","kind":"fact","text":"The report with data as of June 30, 2015 lists the directors of Evolve Bank & Trust as Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Forrest N. Jenkins, Scot Lenoir, Lon Magness, John T. Pitts, Jr., W. Scott Stafford and Stephen Valentine, with Scot Lenoir as chairman, Scott Stafford as chief executive and president and John Copeland as executive vice president and chief financial officer.","source_ids":["src-070"],"entity_ids":["evolve","al-bright","donald-clanton","lewis-holland","forrest-jenkins","scot-lenoir","lon-magness","john-pitts","scott-stafford","steve-valentine","john-copeland"],"qualification":"","response":"","outcome":""},"reading":"Fact: The report with data as of June 30, 2015 lists the directors of Evolve Bank & Trust as Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Forrest N. Jenkins, Scot Lenoir, Lon Magness, John T. Pitts, Jr., W. Scott Stafford and Stephen Valentine, with Scot Lenoir as chairman, Scott Stafford as chief executive and president and John Copeland as executive vice president and chief financial officer."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-2023-2024","record":{"id":"c-brd-2023-2024","kind":"fact","text":"The reports with data as of June 30, 2023 and June 30, 2024 list the same nine directors of Evolve Bank & Trust: Alvinor Bright, Jr., Donald Clanton, Lewis Holland, B. Scot Lenoir, Lon Magness, John T. Pitts, Jr., Scott Stafford, Stephen Valentine and Monica Wharton. Both name B. Scot Lenoir as chairman, Scott Stafford as chief executive, Mark Mosteller as executive vice president and chief financial officer and Robin Bedsole as controller.","source_ids":["src-039","src-108"],"entity_ids":["evolve","al-bright","donald-clanton","lewis-holland","scot-lenoir","lon-magness","john-pitts","scott-stafford","steve-valentine","monica-wharton","mark-mosteller","robin-bedsole"],"qualification":"","response":"","outcome":""},"reading":"Fact: The reports with data as of June 30, 2023 and June 30, 2024 list the same nine directors of Evolve Bank & Trust: Alvinor Bright, Jr., Donald Clanton, Lewis Holland, B. Scot Lenoir, Lon Magness, John T. Pitts, Jr., Scott Stafford, Stephen Valentine and Monica Wharton. Both name B. Scot Lenoir as chairman, Scott Stafford as chief executive, Mark Mosteller as executive vice president and chief financial officer and Robin Bedsole as controller."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-2025","record":{"id":"c-brd-2025","kind":"fact","text":"In the report with data as of June 30, 2025, the directors of Evolve Bank & Trust are Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Lon Magness, John T. Pitts, Jr. and Stephen Valentine; B. Scot Lenoir, Scott Stafford and Monica Wharton are no longer listed. The officers shown are Mark Mosteller as president and chief financial officer, and Hank Word and Joelle Weltzin, each under the label 'EVP/Gen Coun/Sec'.","source_ids":["src-024"],"entity_ids":["evolve","al-bright","donald-clanton","lewis-holland","lon-magness","john-pitts","steve-valentine","mark-mosteller","hank-word","joelle-weltzin","scot-lenoir","scott-stafford","monica-wharton"],"qualification":"Other records describe Weltzin as general counsel and corporate secretary and Word as head of the Open Banking Division; the identical label for both appears to be a duplication in the printed report.","response":"","outcome":""},"reading":"Fact: In the report with data as of June 30, 2025, the directors of Evolve Bank & Trust are Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Lon Magness, John T. Pitts, Jr. and Stephen Valentine; B. Scot Lenoir, Scott Stafford and Monica Wharton are no longer listed. The officers shown are Mark Mosteller as president and chief financial officer, and Hank Word and Joelle Weltzin, each under the label 'EVP/Gen Coun/Sec'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-mississippi-2022","record":{"id":"c-brd-mississippi-2022","kind":"fact","text":"The bank's 2022 annual report to the Mississippi Secretary of State lists John Freeman as president, Henry A. Barham III as secretary and Mark Mosteller as chief financial officer, and B. Scot Lenoir, Don Clanton, John T. Pitts, Lewis Holland, Lon Magness, Steve Valentine and Al Bright as directors.","source_ids":["src-101"],"entity_ids":["evolve","john-freeman","henry-barham","mark-mosteller","scot-lenoir","donald-clanton","john-pitts","lewis-holland","lon-magness","steve-valentine","al-bright"],"qualification":"The filing does not list Scott Stafford, whom other records name as chief executive, or Monica Wharton, who joined the board in October 2021. It spells the secretary's name 'Barnham'; the holding company's Florida filing spells it 'Barham'. Bank materials describe Freeman as president of the bank's Banking Division rather than of the whole bank.","response":"","outcome":""},"reading":"Fact: The bank's 2022 annual report to the Mississippi Secretary of State lists John Freeman as president, Henry A. Barham III as secretary and Mark Mosteller as chief financial officer, and B. Scot Lenoir, Don Clanton, John T. Pitts, Lewis Holland, Lon Magness, Steve Valentine and Al Bright as directors."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-kit-2024-board","record":{"id":"c-brd-kit-2024-board","kind":"fact","text":"The bank's 2024 Investor Relations kit lists as its board of directors B. Scot Lenoir (chief executive of Evolve Bancorp, Inc., who founded Evolve Bank & Trust in 2004 and also served as chairman), W. Scott Stafford (president and chief executive of the bank), Donald B. Clanton (formerly president of the bank's SBA Lending Division), Al Bright, Lewis E. Holland, Lon Magness, John T. Pitts Jr. and Stephen Valentine, a director of Evolve Bancorp, Inc.","source_ids":["src-005"],"entity_ids":["evolve","evolve-bancorp","scot-lenoir","scott-stafford","donald-clanton","al-bright","lewis-holland","lon-magness","john-pitts","steve-valentine"],"qualification":"","response":"","outcome":""},"reading":"Fact: The bank's 2024 Investor Relations kit lists as its board of directors B. Scot Lenoir (chief executive of Evolve Bancorp, Inc., who founded Evolve Bank & Trust in 2004 and also served as chairman), W. Scott Stafford (president and chief executive of the bank), Donald B. Clanton (formerly president of the bank's SBA Lending Division), Al Bright, Lewis E. Holland, Lon Magness, John T. Pitts Jr. and Stephen Valentine, a director of Evolve Bancorp, Inc."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-kit-2024-management","record":{"id":"c-brd-kit-2024-management","kind":"fact","text":"The same 2024 kit lists among senior management Mark Mosteller (executive vice president and chief financial officer, at the bank since 2015), Joelle Weltzin (senior vice president and general counsel), Hank Word (president of Open Banking, who joined in 2014 and was earlier the bank's first chief technology officer), W. Christopher Staab (chief technology officer), Peter Moenickheim (chief risk officer), Thomas E. Holmes, Jr. (chief marketing and communications officer), John C. Freeman (president of the Banking Division) and Randy Reynolds (president of the Arkansas Banking Division).","source_ids":["src-005"],"entity_ids":["evolve","mark-mosteller","joelle-weltzin","hank-word","christopher-staab","peter-moenickheim","thomas-holmes","john-freeman","randy-reynolds"],"qualification":"","response":"","outcome":""},"reading":"Fact: The same 2024 kit lists among senior management Mark Mosteller (executive vice president and chief financial officer, at the bank since 2015), Joelle Weltzin (senior vice president and general counsel), Hank Word (president of Open Banking, who joined in 2014 and was earlier the bank's first chief technology officer), W. Christopher Staab (chief technology officer), Peter Moenickheim (chief risk officer), Thomas E. Holmes, Jr. (chief marketing and communications officer), John C. Freeman (president of the Banking Division) and Randy Reynolds (president of the Arkansas Banking Division)."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-kit-2023","record":{"id":"c-brd-kit-2023","kind":"fact","text":"The bank's 2023 Investor Relations kit includes Monica Wharton, then executive vice president and chief administrative officer of Methodist LeBonheur Healthcare, among the directors, and lists Robert Ducklo as general counsel and corporate secretary (he joined in 2022 after 15 years at FHN Financial, the capital markets division of First Horizon Bank), Cecilia Russell as senior vice president and chief compliance officer (previously an internal audit manager at The Bancorp, Inc.) and Robin Bedsole as corporate controller (at the bank since 2016).","source_ids":["src-020"],"entity_ids":["evolve","monica-wharton","robert-ducklo","cecilia-russell","robin-bedsole","methodist-le-bonheur"],"qualification":"","response":"","outcome":""},"reading":"Fact: The bank's 2023 Investor Relations kit includes Monica Wharton, then executive vice president and chief administrative officer of Methodist LeBonheur Healthcare, among the directors, and lists Robert Ducklo as general counsel and corporate secretary (he joined in 2022 after 15 years at FHN Financial, the capital markets division of First Horizon Bank), Cecilia Russell as senior vice president and chief compliance officer (previously an internal audit manager at The Bancorp, Inc.) and Robin Bedsole as corporate controller (at the bank since 2016)."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-wharton-2021","record":{"id":"c-brd-wharton-2021","kind":"fact","text":"On October 12, 2021 Evolve Bank & Trust announced that it had appointed Monica Wharton, executive vice president and chief administrative officer of Methodist LeBonheur Healthcare, to its board of directors; Scot Lenoir was quoted as chairman.","source_ids":["src-007"],"entity_ids":["evolve","monica-wharton","scot-lenoir","methodist-le-bonheur"],"qualification":"","response":"","outcome":""},"reading":"Fact: On October 12, 2021 Evolve Bank & Trust announced that it had appointed Monica Wharton, executive vice president and chief administrative officer of Methodist LeBonheur Healthcare, to its board of directors; Scot Lenoir was quoted as chairman."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-director-tenures","record":{"id":"c-brd-director-tenures","kind":"fact","text":"Several directors' own disclosures date their board service: Donald B. Clanton reported joining the board in 2005, John T. Pitts Jr. reported board membership since January 1, 2008 in his FINRA BrokerCheck record, and Al Bright's law-firm profile gives his board service as 2015 to the present. A 2013 annual report of Buckeye Technologies described Lewis E. Holland as a director of Evolve Bank & Trust.","source_ids":["src-023","src-102","src-056","src-107"],"entity_ids":["evolve","donald-clanton","john-pitts","al-bright","lewis-holland","bass-berry-sims","buckeye"],"qualification":"","response":"","outcome":""},"reading":"Fact: Several directors' own disclosures date their board service: Donald B. Clanton reported joining the board in 2005, John T. Pitts Jr. reported board membership since January 1, 2008 in his FINRA BrokerCheck record, and Al Bright's law-firm profile gives his board service as 2015 to the present. A 2013 annual report of Buckeye Technologies described Lewis E. Holland as a director of Evolve Bank & Trust."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-jenkins","record":{"id":"c-brd-jenkins","kind":"fact","text":"Forrest N. Jenkins is listed as a director of Evolve Bank & Trust in the regulator's report with data as of June 30, 2015. His obituary (1938–2020) states that he came out of retirement to serve on the bank's board and, while a director, was recruited to be president of the bank's Arkansas Banking Division; it describes him as a former chairman and president of the former Citizens Bank in Marion, Arkansas.","source_ids":["src-089","src-070"],"entity_ids":["forrest-jenkins","evolve","citizens-bank-marion"],"qualification":"","response":"","outcome":""},"reading":"Fact: Forrest N. Jenkins is listed as a director of Evolve Bank & Trust in the regulator's report with data as of June 30, 2015. His obituary (1938–2020) states that he came out of retirement to serve on the bank's board and, while a director, was recruited to be president of the bank's Arkansas Banking Division; it describes him as a former chairman and president of the former Citizens Bank in Marion, Arkansas."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-freeman","record":{"id":"c-brd-freeman","kind":"fact","text":"John C. Freeman is described in the bank's 2023 and 2024 Investor Relations kits as president of its Banking Division, a former president of Liberty Bank in Jonesboro, Arkansas, and chairman of the Arkansas Bankers Association board. The Arkansas regulator's 2015 report lists a John Freeman of Evolve Bank & Trust as a member of the State Banking Board with a term expiring December 31, 2015.","source_ids":["src-020","src-070","src-005"],"entity_ids":["john-freeman","evolve","liberty-bank","arkansas-bankers-association"],"qualification":"","response":"","outcome":""},"reading":"Fact: John C. Freeman is described in the bank's 2023 and 2024 Investor Relations kits as president of its Banking Division, a former president of Liberty Bank in Jonesboro, Arkansas, and chairman of the Arkansas Bankers Association board. The Arkansas regulator's 2015 report lists a John Freeman of Evolve Bank & Trust as a member of the State Banking Board with a term expiring December 31, 2015."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-fed-signatories","record":{"id":"c-brd-fed-signatories","kind":"fact","text":"The Federal Reserve's cease-and-desist order effective June 11, 2024 was signed for Evolve Bancorp, Inc. by Scot Lenoir as chairman of the board and for Evolve Bank & Trust by Scott Stafford as president and chief executive officer; its address block names B. Scot Lenoir as chairman of the board of both companies.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp","scot-lenoir","scott-stafford"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Federal Reserve's cease-and-desist order effective June 11, 2024 was signed for Evolve Bancorp, Inc. by Scot Lenoir as chairman of the board and for Evolve Bank & Trust by Scott Stafford as president and chief executive officer; its address block names B. Scot Lenoir as chairman of the board of both companies."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-cro-notice","record":{"id":"c-brd-cro-notice","kind":"fact","text":"The Federal Reserve's H.2 release covering applications received in the week ending February 3, 2024 records a notice by Evolve Bank & Trust under the federal rules for changes in senior executive officers to appoint Peter Moenickheim as chief risk officer.","source_ids":["src-019"],"entity_ids":["evolve","peter-moenickheim"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Federal Reserve's H.2 release covering applications received in the week ending February 3, 2024 records a notice by Evolve Bank & Trust under the federal rules for changes in senior executive officers to appoint Peter Moenickheim as chief risk officer."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-lenoir-steps-down","record":{"id":"c-brd-lenoir-steps-down","kind":"attributed","text":"A fintech industry newsletter reported on February 4, 2025 that Scot Lenoir, chairman for 20 years, had stepped down from that role 'last July', that is, in July 2024, and now described himself as the bank's founder.","source_ids":["src-011","src-024"],"entity_ids":["scot-lenoir","evolve"],"qualification":"Newsletter account citing a bank spokesperson; the regulator's report with data as of June 30, 2025 no longer lists Lenoir as a director.","response":"An Evolve spokesperson told the newsletter that he remained involved in day-to-day operations.","outcome":""},"reading":"Attributed: A fintech industry newsletter reported on February 4, 2025 that Scot Lenoir, chairman for 20 years, had stepped down from that role 'last July', that is, in July 2024, and now described himself as the bank's founder."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-feb-2025-memo","record":{"id":"c-brd-feb-2025-memo","kind":"attributed","text":"According to an internal memo reported by a fintech industry newsletter on February 4, 2025, the bank elevated chief financial officer Mark Mosteller, a ten-year Evolve veteran, to president, replacing Scott Stafford, who had decided to 'step away from the day-to-day bank operations'; Mosteller kept the CFO role. The memo also promoted Hank Word, chief technology officer and president of the Open Banking Division, and Joelle Weltzin, who joined in March 2024, to executive vice president.","source_ids":["src-011","src-024","src-008"],"entity_ids":["evolve","mark-mosteller","scott-stafford","hank-word","joelle-weltzin"],"qualification":"Newsletter report of an internal memo.","response":"","outcome":"The Arkansas regulator's report with data as of June 30, 2025 lists Mosteller as president and chief financial officer and Word and Weltzin each under the label 'EVP/Gen Coun/Sec'; on August 13, 2025 the bank said all three would remain in their roles under its new chief executive."},"reading":"Attributed: According to an internal memo reported by a fintech industry newsletter on February 4, 2025, the bank elevated chief financial officer Mark Mosteller, a ten-year Evolve veteran, to president, replacing Scott Stafford, who had decided to 'step away from the day-to-day bank operations'; Mosteller kept the CFO role. The memo also promoted Hank Word, chief technology officer and president of the Open Banking Division, and Joelle Weltzin, who joined in March 2024, to executive vice president."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-stafford-retired","record":{"id":"c-brd-stafford-retired","kind":"attributed","text":"A business-profile aggregator updated in October 2026 describes W. Scott Stafford as a former president and chief executive of Evolve Bank & Trust who retired in 2025.","source_ids":["src-098"],"entity_ids":["scott-stafford","evolve"],"qualification":"Aggregator profile; the record contains no bank announcement of Stafford's retirement.","response":"","outcome":""},"reading":"Attributed: A business-profile aggregator updated in October 2026 describes W. Scott Stafford as a former president and chief executive of Evolve Bank & Trust who retired in 2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-hartheimer-appointed","record":{"id":"c-brd-hartheimer-appointed","kind":"fact","text":"On August 13, 2025 Evolve Bank & Trust announced that its board had unanimously chosen Robert 'Bob' Hartheimer as chief executive, effective immediately. Board chairman Steve Valentine called the appointment 'a turning point for Evolve'. The announcement said president and chief financial officer Mark Mosteller, Open Banking Division president Hank Word and general counsel and corporate secretary Joelle Weltzin would remain in their roles and report to Hartheimer.","source_ids":["src-004","src-008"],"entity_ids":["evolve","robert-hartheimer","steve-valentine","mark-mosteller","hank-word","joelle-weltzin"],"qualification":"","response":"","outcome":""},"reading":"Fact: On August 13, 2025 Evolve Bank & Trust announced that its board had unanimously chosen Robert 'Bob' Hartheimer as chief executive, effective immediately. Board chairman Steve Valentine called the appointment 'a turning point for Evolve'. The announcement said president and chief financial officer Mark Mosteller, Open Banking Division president Hank Word and general counsel and corporate secretary Joelle Weltzin would remain in their roles and report to Hartheimer."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-word-leaves","record":{"id":"c-brd-word-leaves","kind":"attributed","text":"A fintech industry newsletter reported on September 14, 2025 that Hank Word, president of the Open Banking Division, was leaving the bank; its sources said he resigned voluntarily.","source_ids":["src-026"],"entity_ids":["hank-word","evolve"],"qualification":"Newsletter report based on unnamed sources.","response":"An Evolve representative declined to comment on personnel matters and did not say who would lead the fintech unit.","outcome":""},"reading":"Attributed: A fintech industry newsletter reported on September 14, 2025 that Hank Word, president of the Open Banking Division, was leaving the bank; its sources said he resigned voluntarily."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-johnston","record":{"id":"c-brd-johnston","kind":"fact","text":"On October 2, 2025 the bank announced the appointment of Alex Johnston as senior vice president and head of Open Banking; the release quoted Bob Hartheimer as chief executive.","source_ids":["src-053"],"entity_ids":["evolve","alex-johnston","robert-hartheimer"],"qualification":"","response":"","outcome":""},"reading":"Fact: On October 2, 2025 the bank announced the appointment of Alex Johnston as senior vice president and head of Open Banking; the release quoted Bob Hartheimer as chief executive."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-after-hartheimer","record":{"id":"c-brd-after-hartheimer","kind":"fact","text":"After dismissing Hartheimer in October 2025, the bank said its Executive Leadership Team of president and chief financial officer Mark Mosteller and executive vice president and general counsel Joelle Weltzin would oversee operations and strategic direction, as they had before August. A February 3, 2026 release announcing Arlon Duke as senior vice president and chief technology officer quoted Mosteller as president and CFO.","source_ids":["src-014","src-097"],"entity_ids":["evolve","mark-mosteller","joelle-weltzin","arlon-duke","robert-hartheimer"],"qualification":"","response":"","outcome":""},"reading":"Fact: After dismissing Hartheimer in October 2025, the bank said its Executive Leadership Team of president and chief financial officer Mark Mosteller and executive vice president and general counsel Joelle Weltzin would oversee operations and strategic direction, as they had before August. A February 3, 2026 release announcing Arlon Duke as senior vice president and chief technology officer quoted Mosteller as president and CFO."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-no-new-ceo","record":{"id":"c-brd-no-new-ceo","kind":"fact","text":"The retained copy of the news page of the bank's website shows leadership announcements for Arlon Duke (February 2026) and Alex Johnston (October 2025) but no announcement of a new chief executive after Hartheimer's dismissal.","source_ids":["src-114"],"entity_ids":["evolve","arlon-duke","alex-johnston"],"qualification":"This describes one retrieved page; it does not exclude an appointment announced elsewhere.","response":"","outcome":""},"reading":"Fact: The retained copy of the news page of the bank's website shows leadership announcements for Arlon Duke (February 2026) and Alex Johnston (October 2025) but no announcement of a new chief executive after Hartheimer's dismissal."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brd-holmes","record":{"id":"c-brd-holmes","kind":"fact","text":"In a public post, Thomas E. Holmes, Jr. announced that he was stepping away from his role as chief marketing and communications officer of Evolve Bank & Trust, writing that the past year had presented 'significant personal and professional challenges' and that he had chosen 'to prioritize my integrity and well-being'. An online encyclopedia dates his resignation to October 2024.","source_ids":["src-048","src-004"],"entity_ids":["thomas-holmes","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: In a public post, Thomas E. Holmes, Jr. announced that he was stepping away from his role as chief marketing and communications officer of Evolve Bank & Trust, writing that the past year had presented 'significant personal and professional challenges' and that he had chosen 'to prioritize my integrity and well-being'. An online encyclopedia dates his resignation to October 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-valentine","record":{"id":"c-ppl-valentine","kind":"fact","text":"According to the bank's 2024 Investor Relations kit, Stephen Valentine, a director of Evolve Bancorp, Inc., provides board-level and executive consulting to companies in the distribution, consumer and technology industries; he was previously an executive with IBM and served AutoZone as senior vice president of business development and as chief information officer.","source_ids":["src-005"],"entity_ids":["steve-valentine","evolve-bancorp","ibm","autozone"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the bank's 2024 Investor Relations kit, Stephen Valentine, a director of Evolve Bancorp, Inc., provides board-level and executive consulting to companies in the distribution, consumer and technology industries; he was previously an executive with IBM and served AutoZone as senior vice president of business development and as chief information officer."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-clanton","record":{"id":"c-ppl-clanton","kind":"fact","text":"Donald B. Clanton, a director since 2005, formerly led the bank's SBA Lending Division. The 2024 kit says he retired in 2017 as chief operating officer of Duncan-Williams after serving as its executive vice president of debt capital markets, and was earlier president of Commerce Investment Corporation, a subsidiary of National Bank of Commerce. His FINRA BrokerCheck record shows registration with Duncan-Williams, Inc. from February 2002 to January 2018 and no disclosed customer complaints, regulatory actions or similar events.","source_ids":["src-023","src-005"],"entity_ids":["donald-clanton","evolve","duncan-williams","commerce-investment-corp","national-bank-of-commerce"],"qualification":"","response":"","outcome":""},"reading":"Fact: Donald B. Clanton, a director since 2005, formerly led the bank's SBA Lending Division. The 2024 kit says he retired in 2017 as chief operating officer of Duncan-Williams after serving as its executive vice president of debt capital markets, and was earlier president of Commerce Investment Corporation, a subsidiary of National Bank of Commerce. His FINRA BrokerCheck record shows registration with Duncan-Williams, Inc. from February 2002 to January 2018 and no disclosed customer complaints, regulatory actions or similar events."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-holland","record":{"id":"c-ppl-holland","kind":"fact","text":"Lewis E. Holland's 2024 kit biography describes him as a director of Raymond James Financial Products Group and of USI Alliance, and a former president and chief operating officer of Henry Turley Company, president of the financial enterprise businesses of National Commerce Financial Corporation, and board member of Buckeye Technologies. Buckeye's 2013 annual report states that he was a Buckeye director from September 2005 to August 2013, that he was president of Henry Turley Company from 2001 until September 2009, and that he had earlier been vice chairman and chief financial officer of National Commerce Bancorporation.","source_ids":["src-107","src-005"],"entity_ids":["lewis-holland","raymond-james-financial-products","usi-alliance","henry-turley","national-commerce-financial","buckeye"],"qualification":"","response":"","outcome":""},"reading":"Fact: Lewis E. Holland's 2024 kit biography describes him as a director of Raymond James Financial Products Group and of USI Alliance, and a former president and chief operating officer of Henry Turley Company, president of the financial enterprise businesses of National Commerce Financial Corporation, and board member of Buckeye Technologies. Buckeye's 2013 annual report states that he was a Buckeye director from September 2005 to August 2013, that he was president of Henry Turley Company from 2001 until September 2009, and that he had earlier been vice chairman and chief financial officer of National Commerce Bancorporation."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-holland-companies","record":{"id":"c-ppl-holland-companies","kind":"fact","text":"Raymond James Financial, Inc.'s list of subsidiaries at September 30, 2020 shows Raymond James Financial Products, Inc. as a Tennessee company within the Raymond James group. A 2004 Federal Reserve notice shows that SunTrust Banks, Inc., in connection with its merger with National Commerce Financial Corporation, applied to acquire USI Alliance Corp. of Memphis, a company engaged in leasing and community development activities.","source_ids":["src-105","src-106"],"entity_ids":["raymond-james-financial-products","usi-alliance","national-commerce-financial","suntrust-banks"],"qualification":"","response":"","outcome":""},"reading":"Fact: Raymond James Financial, Inc.'s list of subsidiaries at September 30, 2020 shows Raymond James Financial Products, Inc. as a Tennessee company within the Raymond James group. A 2004 Federal Reserve notice shows that SunTrust Banks, Inc., in connection with its merger with National Commerce Financial Corporation, applied to acquire USI Alliance Corp. of Memphis, a company engaged in leasing and community development activities."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-bright","record":{"id":"c-ppl-bright","kind":"fact","text":"Al Bright, Jr. is a member of the law firm Bass, Berry & Sims in Memphis; the firm's profile of him lists board service at Evolve Bank & Trust from 2015 to the present. The regulator's report with data as of June 30, 2025 lists him as vice chairman of Evolve Bancorp, Inc.","source_ids":["src-056","src-024"],"entity_ids":["al-bright","bass-berry-sims","evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: Al Bright, Jr. is a member of the law firm Bass, Berry & Sims in Memphis; the firm's profile of him lists board service at Evolve Bank & Trust from 2015 to the present. The regulator's report with data as of June 30, 2025 lists him as vice chairman of Evolve Bancorp, Inc."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-magness","record":{"id":"c-ppl-magness","kind":"fact","text":"Lon M. Magness is a principal and the chief compliance officer of Reliant Investment Management, LLC; the firm's page says he was previously president of a bank-affiliated registered investment adviser and head of the portfolio and funds management division of a $20 billion regional bank.","source_ids":["src-057"],"entity_ids":["lon-magness","reliant-investment-management"],"qualification":"","response":"","outcome":""},"reading":"Fact: Lon M. Magness is a principal and the chief compliance officer of Reliant Investment Management, LLC; the firm's page says he was previously president of a bank-affiliated registered investment adviser and head of the portfolio and funds management division of a $20 billion regional bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-pitts","record":{"id":"c-ppl-pitts","kind":"fact","text":"John T. Pitts Jr. has been registered with Stifel, Nicolaus & Company in Memphis since June 5, 2015, according to his FINRA BrokerCheck record, which discloses no customer complaints, regulatory actions or similar events. The 2024 kit says he was earlier executive vice president of National Bank of Commerce's capital markets group, specialising in institutional fixed-income sales.","source_ids":["src-102","src-005"],"entity_ids":["john-pitts","stifel","national-bank-of-commerce"],"qualification":"","response":"","outcome":""},"reading":"Fact: John T. Pitts Jr. has been registered with Stifel, Nicolaus & Company in Memphis since June 5, 2015, according to his FINRA BrokerCheck record, which discloses no customer complaints, regulatory actions or similar events. The 2024 kit says he was earlier executive vice president of National Bank of Commerce's capital markets group, specialising in institutional fixed-income sales."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-stafford","record":{"id":"c-ppl-stafford","kind":"fact","text":"According to the 2024 kit, before joining Evolve W. Scott Stafford was a senior vice president of National Bank of Commerce, a regional bank later absorbed into Truist, and an investment banker with Duncan-Williams, Inc.","source_ids":["src-005"],"entity_ids":["scott-stafford","national-bank-of-commerce","duncan-williams"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the 2024 kit, before joining Evolve W. Scott Stafford was a senior vice president of National Bank of Commerce, a regional bank later absorbed into Truist, and an investment banker with Duncan-Williams, Inc."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-mosteller","record":{"id":"c-ppl-mosteller","kind":"fact","text":"Mark Mosteller joined Evolve in 2015. The 2024 kit says he was previously executive vice president and chief financial officer of GTx, Inc., a public biopharmaceutical company, and earlier chief operating officer of Union Planters Mortgage.","source_ids":["src-005"],"entity_ids":["mark-mosteller","evolve","gtx","union-planters-mortgage"],"qualification":"","response":"","outcome":""},"reading":"Fact: Mark Mosteller joined Evolve in 2015. The 2024 kit says he was previously executive vice president and chief financial officer of GTx, Inc., a public biopharmaceutical company, and earlier chief operating officer of Union Planters Mortgage."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-wharton","record":{"id":"c-ppl-wharton","kind":"fact","text":"Monica Wharton is executive vice president and chief operating officer of Methodist Le Bonheur Healthcare in Memphis, where she was executive vice president and chief administrative officer from 2020 to 2023 and senior vice president and chief legal officer from 2017 to 2020; she was earlier chief legal officer and general counsel of Regional One Health.","source_ids":["src-099"],"entity_ids":["monica-wharton","methodist-le-bonheur","regional-one-health"],"qualification":"","response":"","outcome":""},"reading":"Fact: Monica Wharton is executive vice president and chief operating officer of Methodist Le Bonheur Healthcare in Memphis, where she was executive vice president and chief administrative officer from 2020 to 2023 and senior vice president and chief legal officer from 2017 to 2020; she was earlier chief legal officer and general counsel of Regional One Health."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-word-tabapay","record":{"id":"c-ppl-word-tabapay","kind":"attributed","text":"Hank Word's public professional profile lists TabaPay, a payments company that the bank names among its Open Banking partners, as his current company.","source_ids":["src-100"],"entity_ids":["hank-word","tabapay"],"qualification":"The public profile shows the company name only; the role and start date are not visible in the retained copy.","response":"","outcome":""},"reading":"Attributed: Hank Word's public professional profile lists TabaPay, a payments company that the bank names among its Open Banking partners, as his current company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-hartheimer-career","record":{"id":"c-ppl-hartheimer-career","kind":"fact","text":"Before joining Evolve, Robert H. Hartheimer was a senior adviser at the advisory and investment firm Klaros, co-founder and chief regulatory officer of the credit card originator CreditStacks (Jasper) from 2015 to 2020, a managing director of Promontory Financial Group from 2002 to 2008, and an FDIC official: he joined the FDIC in 1991, helped create its Division of Resolutions and later directed it. The bank's announcement said he had been a corporate director of 10 companies.","source_ids":["src-008","src-054"],"entity_ids":["robert-hartheimer","klaros","jasper","promontory","fdic","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Before joining Evolve, Robert H. Hartheimer was a senior adviser at the advisory and investment firm Klaros, co-founder and chief regulatory officer of the credit card originator CreditStacks (Jasper) from 2015 to 2020, a managing director of Promontory Financial Group from 2002 to 2008, and an FDIC official: he joined the FDIC in 1991, helped create its Division of Resolutions and later directed it. The bank's announcement said he had been a corporate director of 10 companies."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ppl-hartheimer-boards","record":{"id":"c-ppl-hartheimer-boards","kind":"fact","text":"Repay Holdings Corporation's 2021 proxy statement describes Hartheimer as a Repay director since June 2018, a director and audit committee chairman of Thunder Bridge Capital Partners III Inc. since February 2021, an independent director of the consumer lender and card servicer CardWorks since 2017, an organizer and director nominee of Monzo US from December 2019, and the founder and managing member since 2008 of Hartheimer LLC, a consultancy. It lists earlier board seats at Thunder Bridge Acquisition II, Ltd. (2019 to June 2021), Lending Club Asset Management (2016 to 2019) and Higher One Holdings (2012 to 2016).","source_ids":["src-054"],"entity_ids":["robert-hartheimer","repay","thunder-bridge-iii","cardworks","monzo-us","hartheimer-llc","thunder-bridge-ii","lending-club-am","higher-one"],"qualification":"","response":"","outcome":""},"reading":"Fact: Repay Holdings Corporation's 2021 proxy statement describes Hartheimer as a Repay director since June 2018, a director and audit committee chairman of Thunder Bridge Capital Partners III Inc. since February 2021, an independent director of the consumer lender and card servicer CardWorks since 2017, an organizer and director nominee of Monzo US from December 2019, and the founder and managing member since 2008 of Hartheimer LLC, a consultancy. It lists earlier board seats at Thunder Bridge Acquisition II, Ltd. (2019 to June 2021), Lending Club Asset Management (2016 to 2019) and Higher One Holdings (2012 to 2016)."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fnd-lenoir-bio","record":{"id":"c-fnd-lenoir-bio","kind":"fact","text":"According to the bank's 2024 kit, B. Scot Lenoir rose to chief executive and president of First Mercantile Trust Company, a financial institution with more than $3 billion in assets, arranged its sale to a publicly traded company and, after the sale in 2000, raised the initial capital for Evolve Bancorp, Inc.; he is the founder and chief executive officer of Evolve Bancorp. A regional business publication reported in 2005 that his family had sold First Mercantile Trust, which managed more than $3 billion in pension and profit-sharing assets, to National Commerce Bancorp of Memphis in 2000.","source_ids":["src-005","src-033"],"entity_ids":["scot-lenoir","first-mercantile","evolve-bancorp","national-commerce-financial"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the bank's 2024 kit, B. Scot Lenoir rose to chief executive and president of First Mercantile Trust Company, a financial institution with more than $3 billion in assets, arranged its sale to a publicly traded company and, after the sale in 2000, raised the initial capital for Evolve Bancorp, Inc.; he is the founder and chief executive officer of Evolve Bancorp. A regional business publication reported in 2005 that his family had sold First Mercantile Trust, which managed more than $3 billion in pension and profit-sharing assets, to National Commerce Bancorp of Memphis in 2000."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fnd-lenoir-other-roles","record":{"id":"c-fnd-lenoir-other-roles","kind":"attributed","text":"A financial-data aggregator profile of B. Scot Lenoir lists him as founder, chairman, president and chief executive of Evolve Financial Group, Inc. and of Evolve Bancorp, Inc. (both 2004), former chairman of Evolve Bank & Trust, former president and chief executive of American Trust Co. (Tennessee) and former president and director of AFS Investment Advisors, Inc.","source_ids":["src-055"],"entity_ids":["scot-lenoir","evolve-financial-group","evolve-bancorp","evolve","american-trust-co","afs-investment-advisors"],"qualification":"Aggregator profile; the American Trust Co. and AFS Investment Advisors roles are not dated and do not appear in the other retained records.","response":"","outcome":""},"reading":"Attributed: A financial-data aggregator profile of B. Scot Lenoir lists him as founder, chairman, president and chief executive of Evolve Financial Group, Inc. and of Evolve Bancorp, Inc. (both 2004), former chairman of Evolve Bank & Trust, former president and chief executive of American Trust Co. (Tennessee) and former president and director of AFS Investment Advisors, Inc."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fnd-fmt-sale","record":{"id":"c-fnd-fmt-sale","kind":"fact","text":"The Federal Reserve's H.2 release for June 18 to 24, 2000 records approval on June 20, 2000 of National Commerce Bancorporation's application to acquire FMT Holding Company, and thereby engage in trust company activities and employee benefits consulting. A 2004 Federal Reserve notice shows SunTrust Banks, Inc., in its merger with National Commerce Financial Corporation, applying to acquire First Mercantile Trust Company and FMT Capital Management, Inc. of Memphis.","source_ids":["src-093","src-106"],"entity_ids":["national-commerce-financial","first-mercantile","suntrust-banks"],"qualification":"The 2000 release does not use the name First Mercantile; FMT Holding Company is matched to it by the abbreviation, city and year of the sale reported elsewhere.","response":"","outcome":""},"reading":"Fact: The Federal Reserve's H.2 release for June 18 to 24, 2000 records approval on June 20, 2000 of National Commerce Bancorporation's application to acquire FMT Holding Company, and thereby engage in trust company activities and employee benefits consulting. A 2004 Federal Reserve notice shows SunTrust Banks, Inc., in its merger with National Commerce Financial Corporation, applying to acquire First Mercantile Trust Company and FMT Capital Management, Inc. of Memphis."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fnd-kenneth","record":{"id":"c-fnd-kenneth","kind":"attributed","text":"A fintech industry newsletter reports that Kenneth Lenoir, whose firm First Mercantile took over administration of a set of pension plans in January 1994, is the father of Evolve's founder Scot Lenoir; First Mercantile and Kenneth Lenoir were later named as defendants in an earlier suit over those plans, which was dismissed after the parties settled. The Arkansas regulator's report with data as of June 30, 2006 lists Kenneth Lenoir as an executive vice president of Evolve Bank & Trust.","source_ids":["src-015","src-025"],"entity_ids":["kenneth-lenoir","scot-lenoir","first-mercantile","evolve"],"qualification":"The family relationship and the earlier case are reported by the newsletter; the case papers are not in the retained record.","response":"","outcome":""},"reading":"Attributed: A fintech industry newsletter reports that Kenneth Lenoir, whose firm First Mercantile took over administration of a set of pension plans in January 1994, is the father of Evolve's founder Scot Lenoir; First Mercantile and Kenneth Lenoir were later named as defendants in an earlier suit over those plans, which was dismissed after the parties settled. The Arkansas regulator's report with data as of June 30, 2006 lists Kenneth Lenoir as an executive vice president of Evolve Bank & Trust."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fnd-corkys-suit","record":{"id":"c-fnd-corkys-suit","kind":"attributed","text":"In December 2002 Corky's Bar-B-Q and its owners, acting for their own retirement plan and for participants in some 2,300 other 401(k) plans managed by National Bank of Commerce and First Mercantile Trust, sued those institutions, both subsidiaries of National Commerce Financial, together with First Mercantile's chief executive Kenneth Lenoir and its president Bryan Scot Lenoir, in federal court in Memphis, alleging breaches of fiduciary duty and racketeering through undisclosed fees and seeking $700 million. A trade publication reported on January 2, 2003 that the plans' trustees sought restitution of $775 million.","source_ids":["src-095","src-015","src-111"],"entity_ids":["corkys","first-mercantile","national-bank-of-commerce","national-commerce-financial","kenneth-lenoir","scot-lenoir"],"qualification":"These are the plaintiffs' allegations as reported by the press, not findings. The complaint itself is not in the retained record.","response":"National Commerce Financial, the parent of the defendant institutions, said the suit contained 'grossly inaccurate assertions' and 'grossly exaggerated damages' and that the parties would vigorously defend it; a First Mercantile spokesman denied the complaint's statement that Kenneth Lenoir had been terminated.","outcome":"A fintech industry newsletter later reported that the suit was settled for $18 million; no settlement document is in the retained record.","adverse_subject_ids":["scot-lenoir","kenneth-lenoir","first-mercantile"]},"reading":"Attributed: In December 2002 Corky's Bar-B-Q and its owners, acting for their own retirement plan and for participants in some 2,300 other 401(k) plans managed by National Bank of Commerce and First Mercantile Trust, sued those institutions, both subsidiaries of National Commerce Financial, together with First Mercantile's chief executive Kenneth Lenoir and its president Bryan Scot Lenoir, in federal court in Memphis, alleging breaches of fiduciary duty and racketeering through undisclosed fees and seeking $700 million. A trade publication reported on January 2, 2003 that the plans' trustees sought restitution of $775 million."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-offshore-evolve-assignments","record":{"id":"c-offshore-evolve-assignments","kind":"unresolved","text":"A published database of offshore-company records, in data it attributes to leaked records and the Barbados corporate registry, lists Evolve Assignments Ltd., incorporated in Barbados on May 26, 2009. Its listed directors include persons recorded as 'Lenoir Bryan Scott' and 'Stafford William Scott', both from May 26, 2009 to September 10, 2014, alongside four other directors.","source_ids":["src-022","src-021"],"entity_ids":["evolve-assignments","scot-lenoir","scott-stafford"],"qualification":"The record does not establish whether these entries refer to Evolve's founder B. Scot Lenoir and former chief executive W. Scott Stafford: the database gives no address, date of birth or other identifier for them, and its publisher states that many people share names and that inclusion in the database does not suggest illegal or improper conduct. No other retained record mentions Evolve Assignments Ltd.","response":"","outcome":""},"reading":"Unresolved: A published database of offshore-company records, in data it attributes to leaked records and the Barbados corporate registry, lists Evolve Assignments Ltd., incorporated in Barbados on May 26, 2009. Its listed directors include persons recorded as 'Lenoir Bryan Scott' and 'Stafford William Scott', both from May 26, 2009 to September 10, 2014, alongside four other directors."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order","record":{"id":"c-reg-order","kind":"fact","text":"Effective June 11, 2024, the Board of Governors of the Federal Reserve System and the Arkansas State Bank Department issued a cease-and-desist order upon consent to Evolve Bancorp, Inc. and Evolve Bank & Trust (Docket Nos. 24-012-B-HC and 24-012-B-SM) under section 8 of the Federal Deposit Insurance Act. The order remains in effect until it is stayed, modified, terminated or suspended in writing by the supervisors.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp","federal-reserve-board","arkansas-state-bank-department"],"qualification":"The companies consented to the order to settle the matter without a formal proceeding, before any notice of charges, hearing or adjudication of issues of fact or law; it is not a court judgment.","response":"","outcome":"","adverse_subject_ids":["evolve","evolve-bancorp"]},"reading":"Fact: Effective June 11, 2024, the Board of Governors of the Federal Reserve System and the Arkansas State Bank Department issued a cease-and-desist order upon consent to Evolve Bancorp, Inc. and Evolve Bank & Trust (Docket Nos. 24-012-B-HC and 24-012-B-SM) under section 8 of the Federal Deposit Insurance Act. The order remains in effect until it is stayed, modified, terminated or suspended in writing by the supervisors."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-findings","record":{"id":"c-reg-order-findings","kind":"fact","text":"The order recites that the Federal Reserve Bank of St. Louis and the Arkansas department found deficiencies in the risk management of the bank's Open Banking Division in a safety-and-soundness examination issued on August 11, 2023; that the Reserve Bank found deficiencies in that division's consumer compliance risk management in an examination issued on August 30, 2023; and that a further examination issued on January 10, 2024 found additional anti-money-laundering deficiencies resulting in a Bank Secrecy Act compliance program violation, as well as deficiencies in compliance with sanctions regulations of the Treasury's Office of Foreign Assets Control (OFAC).","source_ids":["src-003"],"entity_ids":["evolve","federal-reserve-bank-st-louis","arkansas-state-bank-department"],"qualification":"The order also records that the companies had begun remedial action.","response":"","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: The order recites that the Federal Reserve Bank of St. Louis and the Arkansas department found deficiencies in the risk management of the bank's Open Banking Division in a safety-and-soundness examination issued on August 11, 2023; that the Reserve Bank found deficiencies in that division's consumer compliance risk management in an examination issued on August 30, 2023; and that a further examination issued on January 10, 2024 found additional anti-money-laundering deficiencies resulting in a Bank Secrecy Act compliance program violation, as well as deficiencies in compliance with sanctions regulations of the Treasury's Office of Foreign Assets Control (OFAC)."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-baas","record":{"id":"c-reg-order-baas","kind":"fact","text":"The order describes the bank's strategy through its Open Banking Division as primarily offering deposit accounts and payment processing to financial technology companies (fintech partners), which in turn offer financial products to end users directly or through partnerships with other entities.","source_ids":["src-003"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The order describes the bank's strategy through its Open Banking Division as primarily offering deposit accounts and payment processing to financial technology companies (fintech partners), which in turn offer financial products to end users directly or through partnerships with other entities."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-requirements","record":{"id":"c-reg-order-requirements","kind":"fact","text":"The order requires the bank to submit plans acceptable to the supervisors for board oversight, Open Banking Division risk management (including written board approval before onboarding new fintech partners or products), consumer compliance, liquidity and funding concentrations, interest-rate risk, internal audit, Bank Secrecy Act and anti-money-laundering compliance, customer due diligence, transaction monitoring and suspicious activity reporting, and OFAC compliance, with quarterly progress reports. It requires interim monitoring procedures for international wire services within 30 days, and policies ensuring that the ledger and sub-ledger responsibilities of the bank and its fintech partners are clearly defined and maintained, including during a material business disruption.","source_ids":["src-003"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The order requires the bank to submit plans acceptable to the supervisors for board oversight, Open Banking Division risk management (including written board approval before onboarding new fintech partners or products), consumer compliance, liquidity and funding concentrations, interest-rate risk, internal audit, Bank Secrecy Act and anti-money-laundering compliance, customer due diligence, transaction monitoring and suspicious activity reporting, and OFAC compliance, with quarterly progress reports. It requires interim monitoring procedures for international wire services within 30 days, and policies ensuring that the ledger and sub-ledger responsibilities of the bank and its fintech partners are clearly defined and maintained, including during a material business disruption."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-transaction-review","record":{"id":"c-reg-order-transaction-review","kind":"fact","text":"The order requires an independent consultant to review transactions of the bank's fintech partners conducted at, by or through the bank from April 1, 2023 to September 30, 2023 to determine whether suspicious activity was properly identified and reported, and requires the bank to report any reportable matters found that had not been reported before.","source_ids":["src-003"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The order requires an independent consultant to review transactions of the bank's fintech partners conducted at, by or through the bank from April 1, 2023 to September 30, 2023 to determine whether suspicious activity was properly identified and reported, and requires the bank to report any reportable matters found that had not been reported before."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-limits","record":{"id":"c-reg-order-limits","kind":"fact","text":"With immediate effect, the order bars the bank, without the supervisors' prior written approval, from establishing new fintech partners, subsidiaries, business lines, products, programs, services or program managers related to its Open Banking Division, or offering new products to existing fintech partners, and requires a liquidity impact analysis before it exits a fintech relationship. Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest payments on subordinated debentures, and may not incur, increase, prepay or guarantee any debt without the prior written approval of the Reserve Bank, the Board's Director of Supervision and Regulation and the Arkansas department; the holding company must submit annual cash-flow projections.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: With immediate effect, the order bars the bank, without the supervisors' prior written approval, from establishing new fintech partners, subsidiaries, business lines, products, programs, services or program managers related to its Open Banking Division, or offering new products to existing fintech partners, and requires a liquidity impact analysis before it exits a fintech relationship. Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest payments on subordinated debentures, and may not incur, increase, prepay or guarantee any debt without the prior written approval of the Reserve Bank, the Board's Director of Supervision and Regulation and the Arkansas department; the holding company must submit annual cash-flow projections."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-management","record":{"id":"c-reg-order-management","kind":"fact","text":"Under the order, Evolve Bancorp and the bank must comply with the federal notice requirements before appointing any new director or senior executive officer or changing a senior executive officer's position, and with the federal restrictions on indemnification and severance payments.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: Under the order, Evolve Bancorp and the bank must comply with the federal notice requirements before appointing any new director or senior executive officer or changing a senior executive officer's position, and with the federal restrictions on indemnification and severance payments."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-order-in-force","record":{"id":"c-reg-order-in-force","kind":"fact","text":"The Federal Reserve Board's press-release lists for 2025 and for 2026 (through an October 16, 2026 release) include numerous announcements terminating enforcement actions against named banks, but none mentions Evolve Bank & Trust or Evolve Bancorp, Inc.","source_ids":["src-079","src-080"],"entity_ids":["evolve","evolve-bancorp","federal-reserve-board"],"qualification":"This is an absence in published lists, not an official statement of the order's status; the Board does not necessarily announce every modification.","response":"","outcome":""},"reading":"Fact: The Federal Reserve Board's press-release lists for 2025 and for 2026 (through an October 16, 2026 release) include numerous announcements terminating enforcement actions against named banks, but none mentions Evolve Bank & Trust or Evolve Bancorp, Inc."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-coding-error","record":{"id":"c-reg-coding-error","kind":"attributed","text":"A fintech industry newsletter reported in July 2024, and repeated in September 2025, that auditors reviewing Evolve's anti-money-laundering practices had found that the bank had not properly screened international wire transfers for about seven years because of a 'coding error' by Hank Word, then its chief technology officer.","source_ids":["src-026","src-003"],"entity_ids":["evolve","hank-word"],"qualification":"This is the newsletter's account of an audit finding; the audit report is not in the retained record, and no response from the bank or Word to it was found.","response":"","outcome":"The Federal Reserve's June 2024 order required the bank to submit interim transaction-monitoring procedures for international wire services within 30 days and to have an independent consultant review its domestic and international wire activity."},"reading":"Attributed: A fintech industry newsletter reported in July 2024, and repeated in September 2025, that auditors reviewing Evolve's anti-money-laundering practices had found that the bank had not properly screened international wire transfers for about seven years because of a 'coding error' by Hank Word, then its chief technology officer."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-probes","record":{"id":"c-reg-probes","kind":"attributed","text":"In September 2025 a fintech industry newsletter wrote that the FBI, the U.S. Attorney's Office for the Southern District of New York and the Justice Department's Money Laundering and Asset Recovery Section 'appear to be continuing to probe' Evolve and its third-party partners, in relation both to as much as $95 million in missing depositor funds and to transnational money movement through the bank.","source_ids":["src-026"],"entity_ids":["evolve"],"qualification":"The newsletter does not cite a charging document or official statement; no criminal charge against the bank appears in the retained record.","response":"","outcome":""},"reading":"Attributed: In September 2025 a fintech industry newsletter wrote that the FBI, the U.S. Attorney's Office for the Southern District of New York and the Justice Department's Money Laundering and Asset Recovery Section 'appear to be continuing to probe' Evolve and its third-party partners, in relation both to as much as $95 million in missing depositor funds and to transnational money movement through the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-senators-2024","record":{"id":"c-reg-senators-2024","kind":"attributed","text":"On June 28, 2024 Senators Sherrod Brown, Ron Wyden and Tammy Baldwin, among others, wrote to Evolve's chief executive W. Scott Stafford and to Synapse's equity holders, fintech operators and partner banks that they were collectively responsible for customers' frozen funds, pointed to a potential shortfall of $65 to $96 million between what consumers were owed and the funds held for them by Synapse's partner banks, and urged them to restore access to all frozen deposits immediately.","source_ids":["src-060"],"entity_ids":["evolve","scott-stafford","synapse"],"qualification":"A letter from members of Congress setting out their views; it is not a regulatory or judicial finding.","response":"","outcome":""},"reading":"Attributed: On June 28, 2024 Senators Sherrod Brown, Ron Wyden and Tammy Baldwin, among others, wrote to Evolve's chief executive W. Scott Stafford and to Synapse's equity holders, fintech operators and partner banks that they were collectively responsible for customers' frozen funds, pointed to a potential shortfall of $65 to $96 million between what consumers were owed and the funds held for them by Synapse's partner banks, and urged them to restore access to all frozen deposits immediately."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-senators-2025","record":{"id":"c-reg-senators-2025","kind":"attributed","text":"In an April 22, 2025 letter to Federal Reserve Governor Michelle Bowman, Senators Elizabeth Warren, Tammy Baldwin, Ron Wyden and John Fetterman asserted that the Federal Reserve Board had failed to supervise Evolve appropriately, causing serious financial harm to more than 100,000 consumers whose funds were frozen when Synapse filed for bankruptcy, some of whom had not been made whole because $65 million to $95 million had disappeared. They noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later and that its 2023 consumer compliance examination concluded in August 2023, while the enforcement action came in June 2024.","source_ids":["src-031","src-003"],"entity_ids":["evolve","federal-reserve-board","synapse"],"qualification":"The senators' assertions about supervision are their own assessment, not a finding by the Board or a court.","response":"","outcome":""},"reading":"Attributed: In an April 22, 2025 letter to Federal Reserve Governor Michelle Bowman, Senators Elizabeth Warren, Tammy Baldwin, Ron Wyden and John Fetterman asserted that the Federal Reserve Board had failed to supervise Evolve appropriately, causing serious financial harm to more than 100,000 consumers whose funds were frozen when Synapse filed for bankruptcy, some of whom had not been made whole because $65 million to $95 million had disappeared. They noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later and that its 2023 consumer compliance examination concluded in August 2023, while the enforcement action came in June 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-senators-2025-account","record":{"id":"c-reg-senators-2025-account","kind":"attributed","text":"The April 2025 letter, citing press reports, says that Evolve told Synapse in August 2022 that it intended to end the relationship, that staff at both companies knew of missing funds at least as early as 2023 without notifying customers, and that Evolve had charged fees directly from Synapse customer accounts totalling about $26 million between 2019 and 2023. It adds that reporting suggested a federal grand jury proceeding was under way.","source_ids":["src-031","src-096"],"entity_ids":["evolve","synapse"],"qualification":"These statements are attributed by the senators to news reports; the underlying bank statements and the grand jury matter are not in the retained record.","response":"Evolve's position on the fees, as reported elsewhere, is that it gave Synapse detailed information on every fee charged and that allocating fees to platforms and end users was Synapse's responsibility as program manager.","outcome":""},"reading":"Attributed: The April 2025 letter, citing press reports, says that Evolve told Synapse in August 2022 that it intended to end the relationship, that staff at both companies knew of missing funds at least as early as 2023 without notifying customers, and that Evolve had charged fees directly from Synapse customer accounts totalling about $26 million between 2019 and 2023. It adds that reporting suggested a federal grand jury proceeding was under way."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-reg-warren-step","record":{"id":"c-reg-warren-step","kind":"attributed","text":"On March 23, 2026 Senator Elizabeth Warren, ranking member of the Senate Banking Committee, wrote to Beast Industries about its acquisition of the teen banking app Step, noting that Step describes itself as 'a financial technology company, not a bank' and partners with Evolve Bank & Trust for banking services. She asked why Step had chosen Evolve and whether it knew of Evolve's involvement in the Synapse fallout, its 2024 data breach and the June 2024 Federal Reserve enforcement action, and cited a court mediator's finding that up to $96 million in customer funds could not be located at Evolve or other banks, in part because of poor recordkeeping.","source_ids":["src-058"],"entity_ids":["evolve","step"],"qualification":"A senator's letter of inquiry; the mediator's determination is cited by the letter, not retained in the record.","response":"","outcome":""},"reading":"Attributed: On March 23, 2026 Senator Elizabeth Warren, ranking member of the Senate Banking Committee, wrote to Beast Industries about its acquisition of the teen banking app Step, noting that Step describes itself as 'a financial technology company, not a bank' and partners with Evolve Bank & Trust for banking services. She asked why Step had chosen Evolve and whether it knew of Evolve's involvement in the Synapse fallout, its 2024 data breach and the June 2024 Federal Reserve enforcement action, and cited a court mediator's finding that up to $96 million in customer funds could not be located at Evolve or other banks, in part because of poor recordkeeping."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-flood","record":{"id":"c-enf-flood","kind":"fact","text":"Effective June 15, 2022, the Federal Reserve Board assessed a civil money penalty of $13,950 on Evolve Bank & Trust under the National Flood Insurance Act for a pattern or practice of violations of the Board's flood insurance rules in Regulation H (Docket No. 22-016-CMP-SM). The bank consented to the order without admitting or denying the allegations; W. Scott Stafford signed as president and chief executive, and the penalty was payable to the National Flood Insurance Program. The Board announced it on June 21, 2022.","source_ids":["src-059","src-016"],"entity_ids":["evolve","federal-reserve-board","scott-stafford"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: Effective June 15, 2022, the Federal Reserve Board assessed a civil money penalty of $13,950 on Evolve Bank & Trust under the National Flood Insurance Act for a pattern or practice of violations of the Board's flood insurance rules in Regulation H (Docket No. 22-016-CMP-SM). The bank consented to the order without admitting or denying the allegations; W. Scott Stafford signed as president and chief executive, and the penalty was payable to the National Flood Insurance Program. The Board announced it on June 21, 2022."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-hill","record":{"id":"c-enf-hill","kind":"fact","text":"Effective May 26, 2020, the Federal Reserve Board issued consent orders of prohibition (Docket No. 20-008-E-I) against Aaron K. Hill and Jessica A. Hill, former employees of Evolve Bank & Trust. The order states that from at least October 2017 to November 2018, while managing a mortgage loan production office in Louisville, Kentucky, first for Evolve and then for First Savings Bank, Aaron Hill concealed the couple's ownership of a lead-management vendor used by the office and caused it to overcharge both banks through duplicative or inflated invoices, and that Jessica Hill accepted pay from both banks without reporting to work. Both are barred from participating in the affairs of any insured depository institution without regulatory approval and must cooperate with the Board's investigations of whether enforcement action should be taken against Evolve, First Savings or their affiliated parties.","source_ids":["src-065","src-066"],"entity_ids":["aaron-hill","jessica-hill","evolve","federal-reserve-board"],"qualification":"The Hills consented to the orders without admitting or denying the Board's allegations, and before any adjudication.","response":"","outcome":"","adverse_subject_ids":["aaron-hill","jessica-hill"]},"reading":"Fact: Effective May 26, 2020, the Federal Reserve Board issued consent orders of prohibition (Docket No. 20-008-E-I) against Aaron K. Hill and Jessica A. Hill, former employees of Evolve Bank & Trust. The order states that from at least October 2017 to November 2018, while managing a mortgage loan production office in Louisville, Kentucky, first for Evolve and then for First Savings Bank, Aaron Hill concealed the couple's ownership of a lead-management vendor used by the office and caused it to overcharge both banks through duplicative or inflated invoices, and that Jessica Hill accepted pay from both banks without reporting to work. Both are barred from participating in the affairs of any insured depository institution without regulatory approval and must cooperate with the Board's investigations of whether enforcement action should be taken against Evolve, First Savings or their affiliated parties."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-doj-2016","record":{"id":"c-enf-doj-2016","kind":"fact","text":"On January 21, 2016 the U.S. District Court for the Western District of Tennessee (Judge Samuel H. Mays, Jr.) entered a consent order in United States v. Evolve Bank & Trust (No. 2:16-cv-2040) resolving the Justice Department's claims that the bank violated the Fair Housing Act by discriminating on the basis of disability and the Equal Credit Opportunity Act by discriminating on the basis of receipt of public assistance, by requiring some mortgage applicants to provide a doctor's letter showing that Social Security Disability Insurance and other disability income would continue. The bank agreed to a settlement fund of $86,000 for 50 identified borrowers, to new policies, training and monitoring, with any undistributed money going to housing-counselling organisations.","source_ids":["src-063"],"entity_ids":["evolve","us-doj"],"qualification":"","response":"Evolve denied the allegations and stated that it had treated loan applicants fairly and without regard to impermissible factors such as handicap or disability.","outcome":"The order provided for the case to be dismissed with prejudice once the court's retained jurisdiction ended.","adverse_subject_ids":["evolve"]},"reading":"Fact: On January 21, 2016 the U.S. District Court for the Western District of Tennessee (Judge Samuel H. Mays, Jr.) entered a consent order in United States v. Evolve Bank & Trust (No. 2:16-cv-2040) resolving the Justice Department's claims that the bank violated the Fair Housing Act by discriminating on the basis of disability and the Equal Credit Opportunity Act by discriminating on the basis of receipt of public assistance, by requiring some mortgage applicants to provide a doctor's letter showing that Social Security Disability Insurance and other disability income would continue. The bank agreed to a settlement fund of $86,000 for 50 identified borrowers, to new policies, training and monitoring, with any undistributed money going to housing-counselling organisations."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-doj-2022","record":{"id":"c-enf-doj-2022","kind":"fact","text":"On September 29, 2022 the Justice Department sued Evolve Bank & Trust in the Western District of Tennessee (No. 2:22-cv-02667), alleging that from at least 2014 through 2019 the bank charged Black, Hispanic and individual female mortgage borrowers statistically significantly higher discretionary pricing than comparable white and male borrowers, in violation of the Equal Credit Opportunity Act and the Fair Housing Act. The case followed a Federal Reserve referral of February 8, 2019 based on a review of loans originated in 2014 to 2016. On October 17, 2022 the court (Judge Sheryl H. Lipman) entered a consent order requiring a $1.3 million settlement fund for affected borrowers, a $50,000 civil penalty, revised pricing policies, a fair lending officer and committee, training and monitoring, terminating 90 days after the bank's fourth annual report to the department.","source_ids":["src-062","src-064"],"entity_ids":["evolve","us-doj","federal-reserve-board"],"qualification":"","response":"The bank denied liability and any wrongdoing in its mortgage pricing, stating that its annual pricing tests for 2014 to 2019 showed no pattern of statistically significant disparities that would violate the ECOA or Fair Housing Act.","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: On September 29, 2022 the Justice Department sued Evolve Bank & Trust in the Western District of Tennessee (No. 2:22-cv-02667), alleging that from at least 2014 through 2019 the bank charged Black, Hispanic and individual female mortgage borrowers statistically significantly higher discretionary pricing than comparable white and male borrowers, in violation of the Equal Credit Opportunity Act and the Fair Housing Act. The case followed a Federal Reserve referral of February 8, 2019 based on a review of loans originated in 2014 to 2016. On October 17, 2022 the court (Judge Sheryl H. Lipman) entered a consent order requiring a $1.3 million settlement fund for affected borrowers, a $50,000 civil penalty, revised pricing policies, a fair lending officer and committee, training and monitoring, terminating 90 days after the bank's fourth annual report to the department."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-esop","record":{"id":"c-enf-esop","kind":"fact","text":"In August 2019 the U.S. Department of Labor announced that the U.S. District Court for the Western District of Virginia had ordered Adam Vinoskey, former chief executive of Sentry Equipment Erectors Inc., and Evolve Bank & Trust, which had acted as transactional fiduciary of Sentry's employee stock ownership plan (ESOP), to restore $6,502,500 to the plan. The court found that in December 2010 they approved the ESOP's purchase of Vinoskey's 51,000 shares at $406 per share although the stock had been appraised at $285 in 2009, and that Evolve failed to investigate red flags in the appraisal, breaching its ERISA duties of loyalty and prudence.","source_ids":["src-086","src-015"],"entity_ids":["evolve","sentry-equipment","adam-vinoskey","us-dol"],"qualification":"","response":"","outcome":"A fintech industry newsletter later reported that the amount was lowered to about $1.9 million on appeal; the appellate decision is not in the retained record.","adverse_subject_ids":["evolve"]},"reading":"Fact: In August 2019 the U.S. Department of Labor announced that the U.S. District Court for the Western District of Virginia had ordered Adam Vinoskey, former chief executive of Sentry Equipment Erectors Inc., and Evolve Bank & Trust, which had acted as transactional fiduciary of Sentry's employee stock ownership plan (ESOP), to restore $6,502,500 to the plan. The court found that in December 2010 they approved the ESOP's purchase of Vinoskey's 51,000 shares at $406 per share although the stock had been appraised at $285 in 2009, and that Evolve failed to investigate red flags in the appraisal, breaching its ERISA duties of loyalty and prudence."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-enf-referrals","record":{"id":"c-enf-referrals","kind":"attributed","text":"A fintech industry newsletter reported that the bank's primary federal regulator, the Federal Reserve Bank of St. Louis, had referred Evolve to the Justice Department three times in ten years after finding reason to believe that it had discriminated in its mortgage business, and that a 2016 Department of Labor case arose from a trust-business transaction handled by Kenneth Lenoir.","source_ids":["src-015"],"entity_ids":["evolve","federal-reserve-bank-st-louis","kenneth-lenoir"],"qualification":"Newsletter summary; the retained consent orders document two Justice Department cases.","response":"","outcome":""},"reading":"Attributed: A fintech industry newsletter reported that the bank's primary federal regulator, the Federal Reserve Bank of St. Louis, had referred Evolve to the Justice Department three times in ten years after finding reason to believe that it had discriminated in its mortgage business, and that a 2016 Department of Labor case arose from a trust-business transaction handled by Kenneth Lenoir."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-company","record":{"id":"c-syn-company","kind":"fact","text":"Synapse Financial Technologies, Inc. is a Delaware corporation with its principal place of business in Woodland Hills, California, that provided technology and other services to fintech platforms and partner banks; its founder and chief executive was Sankaet Pathak. Synapse Brokerage LLC was its subsidiary.","source_ids":["src-029","src-052"],"entity_ids":["synapse","sankaet-pathak","synapse-brokerage"],"qualification":"","response":"","outcome":""},"reading":"Fact: Synapse Financial Technologies, Inc. is a Delaware corporation with its principal place of business in Woodland Hills, California, that provided technology and other services to fintech platforms and partner banks; its founder and chief executive was Sankaet Pathak. Synapse Brokerage LLC was its subsidiary."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-agreements","record":{"id":"c-syn-agreements","kind":"fact","text":"According to the complaint the CFPB filed against Synapse on August 21, 2025, Evolve was one of Synapse's partner banks: Synapse executed a Bank Services Agreement with Evolve on or about April 18, 2017 and a Master Bank Services Agreement on or about September 23, 2022, and at least until summer 2023 Synapse gave consumers who opened accounts through fintech platforms a deposit account agreement on Evolve's behalf.","source_ids":["src-029"],"entity_ids":["evolve","synapse","cfpb"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the complaint the CFPB filed against Synapse on August 21, 2025, Evolve was one of Synapse's partner banks: Synapse executed a Bank Services Agreement with Evolve on or about April 18, 2017 and a Master Bank Services Agreement on or about September 23, 2022, and at least until summer 2023 Synapse gave consumers who opened accounts through fintech platforms a deposit account agreement on Evolve's behalf."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-structure","record":{"id":"c-syn-structure","kind":"attributed","text":"FINRA's August 2025 disciplinary complaint describes the arrangement as follows: end users who opened deposit accounts through fintechs entered into account agreements with a deposit bank and placed funds with it; before December 2023 the funds at 'DDA Bank 1' were held in omnibus accounts in the bank's name for the benefit of the end users ('FBO accounts'); the banks kept ledgers only at the omnibus-account level and relied on Synapse's ledgers for individual balances. DDA Bank 1's services agreement with Synapse expired in September 2023, with a wind-down under which it kept providing some services until May 2024.","source_ids":["src-027","src-026"],"entity_ids":["evolve","synapse","finra"],"qualification":"FINRA's complaint does not name the bank; it calls it 'DDA Bank 1', which a fintech industry newsletter identified as apparently Evolve, and its account of the services agreement and migration matches the CFPB complaint, which names Evolve. These are FINRA's allegations against two former brokerage officers, not findings about the bank.","response":"","outcome":""},"reading":"Attributed: FINRA's August 2025 disciplinary complaint describes the arrangement as follows: end users who opened deposit accounts through fintechs entered into account agreements with a deposit bank and placed funds with it; before December 2023 the funds at 'DDA Bank 1' were held in omnibus accounts in the bank's name for the benefit of the end users ('FBO accounts'); the banks kept ledgers only at the omnibus-account level and relied on Synapse's ledgers for individual balances. DDA Bank 1's services agreement with Synapse expired in September 2023, with a wind-down under which it kept providing some services until May 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-ledger-gap","record":{"id":"c-syn-ledger-gap","kind":"attributed","text":"FINRA's complaint alleges that from about 2022 Synapse's ledgers and those of DDA Bank 1 differed substantially, with Synapse's records showing more end-user money at the bank than the bank said it held; that around October 2023 Synapse's biggest customer, a fintech whose end users had about $3 billion at the bank, began partnering directly with the bank; that Synapse contended the bank had migrated about $49 million more than it was entitled to during that transition; and that when Synapse stopped operating in May 2024 its records showed about $92 million more in end-user deposits at the bank than the bank claimed to hold.","source_ids":["src-027"],"entity_ids":["evolve","synapse","finra"],"qualification":"FINRA's complaint does not name the bank; it calls it 'DDA Bank 1', which a fintech industry newsletter identified as apparently Evolve, and its account of the services agreement and migration matches the CFPB complaint, which names Evolve. These are FINRA's allegations against two former brokerage officers, not findings about the bank.","response":"","outcome":""},"reading":"Attributed: FINRA's complaint alleges that from about 2022 Synapse's ledgers and those of DDA Bank 1 differed substantially, with Synapse's records showing more end-user money at the bank than the bank said it held; that around October 2023 Synapse's biggest customer, a fintech whose end users had about $3 billion at the bank, began partnering directly with the bank; that Synapse contended the bank had migrated about $49 million more than it was entitled to during that transition; and that when Synapse stopped operating in May 2024 its records showed about $92 million more in end-user deposits at the bank than the bank claimed to hold."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-2022-warnings","record":{"id":"c-syn-2022-warnings","kind":"attributed","text":"Press reports cited by four senators state that Evolve told Synapse in August 2022 that it intended to end the relationship. A fintech industry newsletter reported that in a 2022 e-mail the bank's Open Banking controller wrote that balances tended 'to differ a couple hundred million on the daily'.","source_ids":["src-031","src-103"],"entity_ids":["evolve","synapse"],"qualification":"Accounts drawn from press reports and e-mails disclosed in litigation; the e-mail itself is not in the retained record.","response":"","outcome":""},"reading":"Attributed: Press reports cited by four senators state that Evolve told Synapse in August 2022 that it intended to end the relationship. A fintech industry newsletter reported that in a 2022 e-mail the bank's Open Banking controller wrote that balances tended 'to differ a couple hundred million on the daily'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-sept-2023","record":{"id":"c-syn-sept-2023","kind":"attributed","text":"According to a business magazine, citing bankruptcy-court records, Synapse told Evolve in September 2023 that an internal investigation had found discrepancies of about $13 million in accounts holding customer funds at Evolve and alleged that Evolve had paid itself fees from customer funds, including some it was not entitled to. On September 25, 2023 Evolve notified Synapse that it was in breach of contract and withheld monthly payments totalling more than $40 million. Two days later Pathak accused Evolve in a letter of 'persistent negligence' and 'misappropriation of consumer funds'; the letter acknowledged that Synapse itself may have 'incorrectly received' $3.25 million from customer accounts.","source_ids":["src-096"],"entity_ids":["evolve","synapse","sankaet-pathak"],"qualification":"These are the parties' competing accounts as reported by the press.","response":"An Evolve spokesperson said any accounting errors were Synapse's responsibility and that the bank had given Synapse detailed information about every fee charged, which Synapse as program manager was supposed to allocate to platforms and end users.","outcome":"According to a business magazine, Synapse committed to pay a little more than half of the $3.25 million and Evolve agreed in an October contract to cover the rest."},"reading":"Attributed: According to a business magazine, citing bankruptcy-court records, Synapse told Evolve in September 2023 that an internal investigation had found discrepancies of about $13 million in accounts holding customer funds at Evolve and alleged that Evolve had paid itself fees from customer funds, including some it was not entitled to. On September 25, 2023 Evolve notified Synapse that it was in breach of contract and withheld monthly payments totalling more than $40 million. Two days later Pathak accused Evolve in a letter of 'persistent negligence' and 'misappropriation of consumer funds'; the letter acknowledged that Synapse itself may have 'incorrectly received' $3.25 million from customer accounts."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-mercury-move","record":{"id":"c-syn-mercury-move","kind":"attributed","text":"A business magazine reported that on the day Evolve ended its relationship with Synapse in September 2023, Synapse learned that Mercury, then about 35% of Synapse's business according to Pathak, would move more than $3 billion of deposits out of Synapse to work directly with Evolve.","source_ids":["src-096"],"entity_ids":["evolve","synapse","mercury","sankaet-pathak"],"qualification":"Press account; FINRA's complaint separately describes Synapse's biggest customer, with about $3 billion at the bank, moving to a direct relationship around October 2023.","response":"","outcome":""},"reading":"Attributed: A business magazine reported that on the day Evolve ended its relationship with Synapse in September 2023, Synapse learned that Mercury, then about 35% of Synapse's business according to Pathak, would move more than $3 billion of deposits out of Synapse to work directly with Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-deficit-known","record":{"id":"c-syn-deficit-known","kind":"attributed","text":"The CFPB's complaint states that at least as of September 2023, if not earlier, both Evolve and Synapse were aware of a deficit of tens of millions of dollars in the funds Evolve was holding for end users, including consumer funds, and that the two companies publicly blamed each other.","source_ids":["src-029"],"entity_ids":["evolve","synapse","cfpb"],"qualification":"Allegations in a complaint against Synapse, to which Evolve is not a party; the deficit's cause remains disputed.","response":"","outcome":"Synapse filed for Chapter 11 bankruptcy on April 22, 2024, and according to the CFPB the dispute was still unresolved when it sued Synapse in August 2025."},"reading":"Attributed: The CFPB's complaint states that at least as of September 2023, if not earlier, both Evolve and Synapse were aware of a deficit of tens of millions of dollars in the funds Evolve was holding for end users, including consumer funds, and that the two companies publicly blamed each other."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-brokerage-program","record":{"id":"c-syn-brokerage-program","kind":"attributed","text":"According to FINRA's complaint, Synapse Brokerage LLC (formerly MVP Global Trading, LLC, a FINRA member since March 2006) was acquired by Synapse in July 2020 and did no business until September 2023, when, as part of Synapse's effort to move away from DDA Bank 1 amid their dispute, it launched a cash management program. Customers first deposited money with a deposit bank, from which it was to be swept to other 'program banks' to maximise deposit-insurance coverage, while Synapse kept the ledger of each customer's holdings.","source_ids":["src-027"],"entity_ids":["synapse-brokerage","synapse","evolve","finra"],"qualification":"FINRA's complaint does not name the bank; it calls it 'DDA Bank 1', which a fintech industry newsletter identified as apparently Evolve, and its account of the services agreement and migration matches the CFPB complaint, which names Evolve. These are FINRA's allegations against two former brokerage officers, not findings about the bank.","response":"","outcome":""},"reading":"Attributed: According to FINRA's complaint, Synapse Brokerage LLC (formerly MVP Global Trading, LLC, a FINRA member since March 2006) was acquired by Synapse in July 2020 and did no business until September 2023, when, as part of Synapse's effort to move away from DDA Bank 1 amid their dispute, it launched a cash management program. Customers first deposited money with a deposit bank, from which it was to be swept to other 'program banks' to maximise deposit-insurance coverage, while Synapse kept the ledger of each customer's holdings."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-migration","record":{"id":"c-syn-migration","kind":"attributed","text":"FINRA alleges that after one fintech ('Fintech 1') notified its users on October 5, 2023, about $200 million belonging to about 650,000 of them moved from DDA Bank 1 to the Synapse Brokerage program within eight days, and that by the end of November 2023 Synapse Brokerage had opened more than two million accounts and received about $388 million. California's financial regulator states that Yotta agreed to move its savings accounts to Synapse Brokerage on or around October 11, 2023, while its customers kept their Evolve routing and account numbers for services such as direct deposit.","source_ids":["src-027","src-052","src-026"],"entity_ids":["evolve","synapse-brokerage","yotta","finra","dfpi"],"qualification":"FINRA's complaint does not name the bank; it calls it 'DDA Bank 1', which a fintech industry newsletter identified as apparently Evolve, and its account of the services agreement and migration matches the CFPB complaint, which names Evolve. These are FINRA's allegations against two former brokerage officers, not findings about the bank. The identification of 'Fintech 1' with Yotta is a fintech newsletter's reading of the complaint.","response":"","outcome":""},"reading":"Attributed: FINRA alleges that after one fintech ('Fintech 1') notified its users on October 5, 2023, about $200 million belonging to about 650,000 of them moved from DDA Bank 1 to the Synapse Brokerage program within eight days, and that by the end of November 2023 Synapse Brokerage had opened more than two million accounts and received about $388 million. California's financial regulator states that Yotta agreed to move its savings accounts to Synapse Brokerage on or around October 11, 2023, while its customers kept their Evolve routing and account numbers for services such as direct deposit."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-evolve-role-after","record":{"id":"c-syn-evolve-role-after","kind":"attributed","text":"The CFPB's complaint states that Evolve was not one of the banks holding Synapse Brokerage deposits; from October 2023 Synapse directed the transfer of participating platforms' end-user funds from Evolve to Synapse Brokerage and on to other partner banks, while the funds of platforms that did not take part stayed at Evolve. Even for users who moved, Evolve continued to sponsor debit cards, to receive direct deposits and other ACH transfers sent to its routing number and to maintain accounts from which Synapse swept funds to the brokerage.","source_ids":["src-029"],"entity_ids":["evolve","synapse","synapse-brokerage","cfpb"],"qualification":"Allegations in the CFPB's complaint against Synapse.","response":"","outcome":""},"reading":"Attributed: The CFPB's complaint states that Evolve was not one of the banks holding Synapse Brokerage deposits; from October 2023 Synapse directed the transfer of participating platforms' end-user funds from Evolve to Synapse Brokerage and on to other partner banks, while the funds of platforms that did not take part stayed at Evolve. Even for users who moved, Evolve continued to sponsor debit cards, to receive direct deposits and other ACH transfers sent to its routing number and to maintain accounts from which Synapse swept funds to the brokerage."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-dec-2023","record":{"id":"c-syn-dec-2023","kind":"attributed","text":"FINRA alleges that around December 31, 2023 DDA Bank 1 stopped sweeping Synapse Brokerage customers' incoming funds into the program and held them in omnibus accounts in Synapse's name, that customers were not told, and that Synapse then began 'reallocating' customer funds between DDA Bank 1 and the program banks by adjusting ledger values without moving money. A fintech industry newsletter reported that the complaint says the bank's FBO accounts were retitled around December 2023 in the name of 'Synapse Financial Technologies' for the benefit of Synapse Brokerage ACH and wire customers, and that Synapse reallocated $85 million of 'Fintech 1' funds in its ledgers from the program banks to the bank.","source_ids":["src-027","src-026"],"entity_ids":["evolve","synapse","synapse-brokerage","finra"],"qualification":"FINRA's complaint does not name the bank; it calls it 'DDA Bank 1', which a fintech industry newsletter identified as apparently Evolve, and its account of the services agreement and migration matches the CFPB complaint, which names Evolve. These are FINRA's allegations against two former brokerage officers, not findings about the bank.","response":"","outcome":""},"reading":"Attributed: FINRA alleges that around December 31, 2023 DDA Bank 1 stopped sweeping Synapse Brokerage customers' incoming funds into the program and held them in omnibus accounts in Synapse's name, that customers were not told, and that Synapse then began 'reallocating' customer funds between DDA Bank 1 and the program banks by adjusting ledger values without moving money. A fintech industry newsletter reported that the complaint says the bank's FBO accounts were retitled around December 2023 in the name of 'Synapse Financial Technologies' for the benefit of Synapse Brokerage ACH and wire customers, and that Synapse reallocated $85 million of 'Fintech 1' funds in its ledgers from the program banks to the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-bankruptcy","record":{"id":"c-syn-bankruptcy","kind":"attributed","text":"Synapse filed for Chapter 11 bankruptcy on April 22, 2024 and asked the court to approve a sale of its business. According to the CFPB's complaint, the buyer required Synapse and Evolve to resolve their dispute and ensure that account balances at Evolve were fully funded, and the two could not resolve it.","source_ids":["src-029"],"entity_ids":["synapse","evolve","cfpb"],"qualification":"The account of the sale condition comes from the CFPB's complaint against Synapse.","response":"","outcome":""},"reading":"Attributed: Synapse filed for Chapter 11 bankruptcy on April 22, 2024 and asked the court to approve a sale of its business. According to the CFPB's complaint, the buyer required Synapse and Evolve to resolve their dispute and ensure that account balances at Evolve were fully funded, and the two could not resolve it."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-freeze","record":{"id":"c-syn-freeze","kind":"attributed","text":"On May 11, 2024, according to the CFPB's complaint, Synapse cut off Evolve's access to the online dashboard showing end users' balances and transactions and stopped sending the daily general-ledger reports; the same day Evolve stopped processing transactions and froze all activity for every end user. FINRA's complaint adds that funds held at the program banks were returned to customers in late May and June 2024, while customer funds at DDA Bank 1, largely Fintech 1 users' money reallocated in the ledger on April 30, remained inaccessible.","source_ids":["src-029","src-027","src-004"],"entity_ids":["evolve","synapse","synapse-brokerage","cfpb","finra"],"qualification":"Allegations in the CFPB and FINRA complaints. An online encyclopedia describes the freeze as lasting five months and locking tens of thousands of customers out of their accounts.","response":"","outcome":"According to FINRA, the bank began releasing funds to Synapse Brokerage customers in November 2024, and customers whose funds were allocated to it recovered only a fraction of them."},"reading":"Attributed: On May 11, 2024, according to the CFPB's complaint, Synapse cut off Evolve's access to the online dashboard showing end users' balances and transactions and stopped sending the daily general-ledger reports; the same day Evolve stopped processing transactions and froze all activity for every end user. FINRA's complaint adds that funds held at the program banks were returned to customers in late May and June 2024, while customer funds at DDA Bank 1, largely Fintech 1 users' money reallocated in the ledger on April 30, remained inaccessible."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-misappropriation-claim","record":{"id":"c-syn-misappropriation-claim","kind":"attributed","text":"An online encyclopedia records that in September 2024 Synapse accused Evolve of misappropriating customer funds.","source_ids":["src-004","src-030"],"entity_ids":["synapse","evolve"],"qualification":"A one-sided accusation in a dispute between the two companies; no court has ruled on it in the retained record.","response":"Evolve told the bankruptcy court that its reconciliation showed Synapse's ledgers were wrong and rejected the former Synapse chief executive's claim that the missing funds are at Evolve.","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Attributed: An online encyclopedia records that in September 2024 Synapse accused Evolve of misappropriating customer funds."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-syn-board-pathak","record":{"id":"c-syn-board-pathak","kind":"attributed","text":"An online encyclopedia, citing a business magazine, reports that Synapse's board considered replacing Pathak in 2023 because of complaints about discrepancies in the company's ledgers of customer funds, but that investors from Andreessen Horowitz argued against it.","source_ids":["src-075"],"entity_ids":["synapse","sankaet-pathak"],"qualification":"Secondary account of internal board deliberations; no board record is in the retained material.","response":"","outcome":""},"reading":"Attributed: An online encyclopedia, citing a business magazine, reports that Synapse's board considered replacing Pathak in 2023 because of complaints about discrepancies in the company's ledgers of customer funds, but that investors from Andreessen Horowitz argued against it."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-ankura","record":{"id":"c-rec-ankura","kind":"fact","text":"Evolve engaged Ankura Consulting Group to reconcile the funds it held for Synapse Brokerage end users using its own records, Federal Reserve records and information from the Chapter 11 trustee. In an update filed with the trustee's November 12, 2024 report, Evolve said the reconciliation was completed on October 18, 2024, that on November 4 it e-mailed about 118,000 Synapse Brokerage end users a link to a reconciliation website showing each user's reconstructed 'Synapse ecosystem balance' and 'Evolve payment' as of May 17, 2024, and that users who disagreed could appeal online; fewer than 4.3% had appealed by November 11, 2024.","source_ids":["src-029","src-030"],"entity_ids":["evolve","ankura","synapse-brokerage"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve engaged Ankura Consulting Group to reconcile the funds it held for Synapse Brokerage end users using its own records, Federal Reserve records and information from the Chapter 11 trustee. In an update filed with the trustee's November 12, 2024 report, Evolve said the reconciliation was completed on October 18, 2024, that on November 4 it e-mailed about 118,000 Synapse Brokerage end users a link to a reconciliation website showing each user's reconstructed 'Synapse ecosystem balance' and 'Evolve payment' as of May 17, 2024, and that users who disagreed could appeal online; fewer than 4.3% had appealed by November 11, 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-rust","record":{"id":"c-rec-rust","kind":"fact","text":"On October 23, 2024 Evolve announced that Rust Consulting, an Exela Technologies brand, would administer payments of the funds the bank had held since the Synapse bankruptcy to Synapse Brokerage end users. Founder Scot Lenoir said the bank had sorted through more than 100 million transaction records to evaluate 'the flawed ledgers from Synapse' and reconstruct end users' positions at Evolve; announcing an earlier milestone in Ankura's work, he said the bank had been committed to the reconciliation 'since we identified significant irregularities in end-user balances reported by Synapse'.","source_ids":["src-038","src-008"],"entity_ids":["evolve","rust-consulting","scot-lenoir","synapse-brokerage","ankura"],"qualification":"","response":"","outcome":""},"reading":"Fact: On October 23, 2024 Evolve announced that Rust Consulting, an Exela Technologies brand, would administer payments of the funds the bank had held since the Synapse bankruptcy to Synapse Brokerage end users. Founder Scot Lenoir said the bank had sorted through more than 100 million transaction records to evaluate 'the flawed ledgers from Synapse' and reconstruct end users' positions at Evolve; announcing an earlier milestone in Ankura's work, he said the bank had been committed to the reconciliation 'since we identified significant irregularities in end-user balances reported by Synapse'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-limits","record":{"id":"c-rec-limits","kind":"fact","text":"In the same court update Evolve said that Ankura's work showed Synapse's ledgers for Synapse Brokerage accounts to be contradicted by Synapse's own transaction data, Federal Reserve data and Evolve's records; that other partner banks had not joined its reconciliation; and that Ankura therefore could not determine where end-user funds were located outside Evolve. Evolve said Synapse had been responsible for tracking the movement and location of funds across its ecosystem and offered to share its transaction data with the other banks.","source_ids":["src-030"],"entity_ids":["evolve","ankura","synapse"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the same court update Evolve said that Ankura's work showed Synapse's ledgers for Synapse Brokerage accounts to be contradicted by Synapse's own transaction data, Federal Reserve data and Evolve's records; that other partner banks had not joined its reconciliation; and that Ankura therefore could not determine where end-user funds were located outside Evolve. Evolve said Synapse had been responsible for tracking the movement and location of funds across its ecosystem and offered to share its transaction data with the other banks."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-trustee-fbo","record":{"id":"c-rec-trustee-fbo","kind":"fact","text":"The Synapse trustee's twelfth status report (Jelena McWilliams, Bankr. C.D. Cal. No. 1:24-bk-10646-MB, November 12, 2024) shows Evolve Bank and Trust holding $46,926,558 of Synapse end users' FBO funds on May 24, 2024, of which $21,000,000 (44%) had been distributed by November 12, 2024, compared with 99% at AMG National Trust; across the four banks, $187,121,489 of $219,049,826 (85%) had been distributed. Evolve also reported distributing $5,662,432 of demand-deposit funds to 42,031 end users of eight platforms, with about $600,000 remaining for 1,042 users.","source_ids":["src-030"],"entity_ids":["evolve","amg-national-trust","lineage-bank","american-bank","synapse"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Synapse trustee's twelfth status report (Jelena McWilliams, Bankr. C.D. Cal. No. 1:24-bk-10646-MB, November 12, 2024) shows Evolve Bank and Trust holding $46,926,558 of Synapse end users' FBO funds on May 24, 2024, of which $21,000,000 (44%) had been distributed by November 12, 2024, compared with 99% at AMG National Trust; across the four banks, $187,121,489 of $219,049,826 (85%) had been distributed. Evolve also reported distributing $5,662,432 of demand-deposit funds to 42,031 end users of eight platforms, with about $600,000 remaining for 1,042 users."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-platforms","record":{"id":"c-rec-platforms","kind":"fact","text":"According to the trustee's report, end users who by November 12, 2024 had elected how to receive more than $21 million of FBO funds from Evolve came from the fintech platforms Juno, YieldStreet, Yotta and Clerkie.","source_ids":["src-030"],"entity_ids":["evolve","juno","yieldstreet","yotta","clerkie"],"qualification":"","response":"","outcome":""},"reading":"Fact: According to the trustee's report, end users who by November 12, 2024 had elected how to receive more than $21 million of FBO funds from Evolve came from the fintech platforms Juno, YieldStreet, Yotta and Clerkie."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-open-letter","record":{"id":"c-rec-open-letter","kind":"attributed","text":"A banking trade publication reported on November 27, 2024 that Evolve, which in October had said it was preparing to disburse roughly $46 million belonging to Synapse end users, stated in an open letter that end users had received, or chosen how to receive, more than $24.5 million; according to the class action filed that week, Evolve said it held less than the Synapse ledger showed for many users, paid them less and pointed to the other partner banks for the missing funds.","source_ids":["src-104"],"entity_ids":["evolve","amg-national-trust","lineage-bank"],"qualification":"Press account of a bank letter and of the plaintiffs' allegations.","response":"AMG and Lineage denied that they held substantial additional funds belonging to fintech users.","outcome":""},"reading":"Attributed: A banking trade publication reported on November 27, 2024 that Evolve, which in October had said it was preparing to disburse roughly $46 million belonging to Synapse end users, stated in an open letter that end users had received, or chosen how to receive, more than $24.5 million; according to the class action filed that week, Evolve said it held less than the Synapse ledger showed for many users, paid them less and pointed to the other partner banks for the missing funds."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-trustee-view","record":{"id":"c-rec-trustee-view","kind":"fact","text":"The trustee reported that Evolve had declined, citing pending litigation, to give her most details of its reconciliation, including individual and aggregate balances, so that she had less information on Evolve's expected distributions than end users did. She noted that Evolve had told some end users it would pay them considerably less than the Synapse ledger showed and said she was disappointed in the results of Evolve's reconciliation to date, while recognising its efforts to make substantial distributions.","source_ids":["src-030"],"entity_ids":["evolve","synapse"],"qualification":"","response":"","outcome":""},"reading":"Fact: The trustee reported that Evolve had declined, citing pending litigation, to give her most details of its reconciliation, including individual and aggregate balances, so that she had less information on Evolve's expected distributions than end users did. She noted that Evolve had told some end users it would pay them considerably less than the Synapse ledger showed and said she was disappointed in the results of Evolve's reconciliation to date, while recognising its efforts to make substantial distributions."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-shortfall","record":{"id":"c-rec-shortfall","kind":"fact","text":"The trustee's November 2024 report kept her aggregate estimate of the shortfall in end-user funds across Synapse's partner banks at $65 million to $95 million. The CFPB's August 2025 complaint states that, with the trustee's assistance, the partner banks determined that together they held less for end users than Synapse's records showed, and gives the trustee's estimate as $60 million to $90 million.","source_ids":["src-030","src-029"],"entity_ids":["synapse","evolve","cfpb"],"qualification":"Neither estimate attributes the shortfall to a particular bank.","response":"","outcome":""},"reading":"Fact: The trustee's November 2024 report kept her aggregate estimate of the shortfall in end-user funds across Synapse's partner banks at $65 million to $95 million. The CFPB's August 2025 complaint states that, with the trustee's assistance, the partner banks determined that together they held less for end users than Synapse's records showed, and gives the trustee's estimate as $60 million to $90 million."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-amg-lineage","record":{"id":"c-rec-amg-lineage","kind":"attributed","text":"In their joint section of the trustee's report, AMG National Trust and Lineage Bank said that, by their summary of Synapse-related transfers with Evolve, Lineage sent Evolve $1,509,088,460.82 and received $210,320,593.25, AMG sent $323,807,726.68 and received $665,007,816.71, for a net flow into Evolve of $957,567,777.54. They called Evolve's suggestion that they might still hold substantial additional funds 'irresponsible and disingenuous', said AMG had paid out more than 99% of its balance, and cited Yotta users who reported an Evolve payment of $579.00 against a reconstructed ecosystem balance of $282,100.","source_ids":["src-030"],"entity_ids":["amg-national-trust","lineage-bank","evolve","yotta"],"qualification":"Gross transfer totals between banks over the life of the programmes; they do not by themselves show what any bank owed end users at the freeze.","response":"Evolve's position is that its reconciliation showed Synapse's ledgers were wrong and that other banks should share transaction data to locate the remaining funds.","outcome":""},"reading":"Attributed: In their joint section of the trustee's report, AMG National Trust and Lineage Bank said that, by their summary of Synapse-related transfers with Evolve, Lineage sent Evolve $1,509,088,460.82 and received $210,320,593.25, AMG sent $323,807,726.68 and received $665,007,816.71, for a net flow into Evolve of $957,567,777.54. They called Evolve's suggestion that they might still hold substantial additional funds 'irresponsible and disingenuous', said AMG had paid out more than 99% of its balance, and cited Yotta users who reported an Evolve payment of $579.00 against a reconstructed ecosystem balance of $282,100."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-later-dispute","record":{"id":"c-rec-later-dispute","kind":"attributed","text":"A banking trade publication reported in April 2025 that Evolve had told many users that they would receive less than the Synapse ledger showed because the missing funds were with other partner banks, that AMG and Lineage argued in a November 12, 2024 letter that an accurate reconciliation was 'impossible' because of Synapse's bulk transfers unrelated to specific users, and that Lineage said it had reconciled its records with Federal Reserve records and returned about 99% of the funds it held.","source_ids":["src-110"],"entity_ids":["evolve","amg-national-trust","lineage-bank","synapse"],"qualification":"Press account of the banks' competing positions.","response":"","outcome":"On January 8, 2026 Evolve said that Ankura's continued review had found further ledger irregularities and that it would distribute more funds to certain end users."},"reading":"Attributed: A banking trade publication reported in April 2025 that Evolve had told many users that they would receive less than the Synapse ledger showed because the missing funds were with other partner banks, that AMG and Lineage argued in a November 12, 2024 letter that an accurate reconciliation was 'impossible' because of Synapse's bulk transfers unrelated to specific users, and that Lineage said it had reconciled its records with Federal Reserve records and returned about 99% of the funds it held."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-payouts-examples","record":{"id":"c-rec-payouts-examples","kind":"attributed","text":"The senators' April 2025 letter, citing press reports, gives examples of shortfalls in payments: a customer with about $130,000 in a fintech account using an Evolve routing number was told in November 2024 that Evolve held $1,182 in her name; a Yotta customer with nearly $50,000 recovered $1.49; and a family that had placed about $280,000 of house-sale proceeds in a Yotta account was told it would receive $500.","source_ids":["src-031"],"entity_ids":["evolve","yotta"],"qualification":"Individual cases reported by the press and repeated by the senators; they show what Evolve said it held for those users, not where the rest of the money went.","response":"","outcome":""},"reading":"Attributed: The senators' April 2025 letter, citing press reports, gives examples of shortfalls in payments: a customer with about $130,000 in a fintech account using an Evolve routing number was told in November 2024 that Evolve held $1,182 in her name; a Yotta customer with nearly $50,000 recovered $1.49; and a family that had placed about $280,000 of house-sale proceeds in a Yotta account was told it would receive $500."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-pennies","record":{"id":"c-rec-pennies","kind":"attributed","text":"A fintech industry newsletter reported in February 2025 that chief financial officer Mark Mosteller had overseen the Ankura reconciliation, which 'purported to show many Synapse end users were entitled to pennies on the dollar, or nothing at all, from Evolve'.","source_ids":["src-011"],"entity_ids":["evolve","mark-mosteller","ankura"],"qualification":"Newsletter account based on unnamed sources.","response":"","outcome":""},"reading":"Attributed: A fintech industry newsletter reported in February 2025 that chief financial officer Mark Mosteller had overseen the Ankura reconciliation, which 'purported to show many Synapse end users were entitled to pennies on the dollar, or nothing at all, from Evolve'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-distributions","record":{"id":"c-rec-distributions","kind":"fact","text":"The CFPB's complaint states that AMG began distributing funds to end users in May 2024 and Evolve and Lineage in June 2024, and that in March 2025 the partner banks reported they were still distributing funds, mostly for very-low-balance accounts without valid addresses and for returned payments.","source_ids":["src-029"],"entity_ids":["evolve","amg-national-trust","lineage-bank","cfpb"],"qualification":"","response":"","outcome":""},"reading":"Fact: The CFPB's complaint states that AMG began distributing funds to end users in May 2024 and Evolve and Lineage in June 2024, and that in March 2025 the partner banks reported they were still distributing funds, mostly for very-low-balance accounts without valid addresses and for returned payments."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-2026-statement","record":{"id":"c-rec-2026-statement","kind":"attributed","text":"On January 8, 2026, some 607 days after the freeze, Evolve posted a statement on its reconciliation website saying that Ankura had continued to review Synapse's records over the past year, had found more end users migrated to Synapse Brokerage than previously disclosed and other ledger irregularities, and that Evolve would distribute funds to certain end users in the coming days. The bank did not disclose the amount.","source_ids":["src-103"],"entity_ids":["evolve","ankura","synapse-brokerage"],"qualification":"Reported by a fintech industry newsletter, which noted that Evolve had told the bankruptcy court that the reconciliation was completed on October 18, 2024.","response":"An Evolve representative did not answer the newsletter's questions about the irregularities or the additional amount to be paid.","outcome":""},"reading":"Attributed: On January 8, 2026, some 607 days after the freeze, Evolve posted a statement on its reconciliation website saying that Ankura had continued to review Synapse's records over the past year, had found more end users migrated to Synapse Brokerage than previously disclosed and other ledger irregularities, and that Evolve would distribute funds to certain end users in the coming days. The bank did not disclose the amount."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-cfpb-judgment","record":{"id":"c-rec-cfpb-judgment","kind":"fact","text":"The CFPB sued Synapse Financial Technologies in its bankruptcy case (Adv. No. 1:25-ap-01052) on August 21, 2025. According to the CFPB, the stipulated final judgment entered on September 12, 2025 includes injunctive relief, among it a ban on selling customer information, and a $1 civil money penalty that allows the Bureau to use its Civil Penalty Fund to compensate harmed consumers.","source_ids":["src-036","src-029"],"entity_ids":["cfpb","synapse"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["synapse"]},"reading":"Fact: The CFPB sued Synapse Financial Technologies in its bankruptcy case (Adv. No. 1:25-ap-01052) on August 21, 2025. According to the CFPB, the stipulated final judgment entered on September 12, 2025 includes injunctive relief, among it a ban on selling customer information, and a $1 civil money penalty that allows the Bureau to use its Civil Penalty Fund to compensate harmed consumers."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-rec-cfpb-fund","record":{"id":"c-rec-cfpb-fund","kind":"fact","text":"In a notice to Yotta customers issued with its May 15, 2026 consent order, California's financial regulator said that on November 28, 2025 the CFPB allocated $46,248,291 from its Civil Penalty Fund to eligible victims of the Synapse bankruptcy, that under the stipulated judgment Yotta customers with a positive balance on May 17, 2024 might claim compensation, and that the claims process had not yet begun. A fintech industry newsletter reported that an analyst at Stifel saw the allocation as possibly reducing any net liability Evolve might face from the Synapse bankruptcy, stressing that this was speculative.","source_ids":["src-037","src-035"],"entity_ids":["cfpb","dfpi","yotta","evolve","synapse"],"qualification":"","response":"","outcome":""},"reading":"Fact: In a notice to Yotta customers issued with its May 15, 2026 consent order, California's financial regulator said that on November 28, 2025 the CFPB allocated $46,248,291 from its Civil Penalty Fund to eligible victims of the Synapse bankruptcy, that under the stipulated judgment Yotta customers with a positive balance on May 17, 2024 might claim compensation, and that the claims process had not yet begun. A fintech industry newsletter reported that an analyst at Stifel saw the allocation as possibly reducing any net liability Evolve might face from the Synapse bankruptcy, stressing that this was speculative."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-yotta-filed","record":{"id":"c-lit-yotta-filed","kind":"fact","text":"On September 13, 2024 Yotta Technologies Inc., a fintech whose customers' accounts were held at Evolve through Synapse, sued Evolve Bancorp, Inc. and Evolve Bank & Trust in the U.S. District Court for the Northern District of California (No. 3:24-cv-06456). On January 23, 2025 Judge Trina L. Thompson approved the parties' stipulation dismissing the holding company, and the case continued against the bank.","source_ids":["src-087"],"entity_ids":["yotta","evolve","evolve-bancorp"],"qualification":"","response":"","outcome":""},"reading":"Fact: On September 13, 2024 Yotta Technologies Inc., a fintech whose customers' accounts were held at Evolve through Synapse, sued Evolve Bancorp, Inc. and Evolve Bank & Trust in the U.S. District Court for the Northern District of California (No. 3:24-cv-06456). On January 23, 2025 Judge Trina L. Thompson approved the parties' stipulation dismissing the holding company, and the case continued against the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-yotta-claims","record":{"id":"c-lit-yotta-claims","kind":"attributed","text":"Yotta's amended complaint alleges fraud by Evolve. A discovery order of January 22, 2026 lists among the alleged misrepresentations the balances and transactions Evolve reported to Yotta through the Synapse interface from 2020 to May 11, 2024, an e-mail from Evolve president Hank Word to Yotta co-founder Adam Moelis on or about September 25, 2023 describing the problems with Synapse as 'some contractual issues' being handled so as to 'protect end users', and a similar e-mail from Scot Lenoir on or about October 3, 2023 saying Yotta could 'transition to another bank'.","source_ids":["src-069","src-088","src-110"],"entity_ids":["yotta","evolve","hank-word","scot-lenoir","adam-moelis"],"qualification":"These are Yotta's allegations as summarised by the court; they have not been adjudicated.","response":"Evolve sought dismissal, arguing (as reported by a banking trade publication) that the complaint fell short on allegations against Evolve and was more about Synapse.","outcome":"On February 18, 2026 the court granted Evolve's motion to dismiss the amended complaint and closed the case on February 19; Yotta appealed to the Ninth Circuit (No. 26-1535) on March 11, 2026, and an appellate mandate was entered on the district docket on October 6, 2026, its content not shown in the retained docket.","adverse_subject_ids":["evolve"]},"reading":"Attributed: Yotta's amended complaint alleges fraud by Evolve. A discovery order of January 22, 2026 lists among the alleged misrepresentations the balances and transactions Evolve reported to Yotta through the Synapse interface from 2020 to May 11, 2024, an e-mail from Evolve president Hank Word to Yotta co-founder Adam Moelis on or about September 25, 2023 describing the problems with Synapse as 'some contractual issues' being handled so as to 'protect end users', and a similar e-mail from Scot Lenoir on or about October 3, 2023 saying Yotta could 'transition to another bank'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-word-declaration","record":{"id":"c-lit-word-declaration","kind":"fact","text":"In support of its motion to dismiss Yotta's amended complaint, Evolve filed under seal a declaration of Hank Word, listed in the docket as the declaration of Harry Alan Word, Jr.","source_ids":["src-087"],"entity_ids":["evolve","hank-word","yotta"],"qualification":"","response":"","outcome":""},"reading":"Fact: In support of its motion to dismiss Yotta's amended complaint, Evolve filed under seal a declaration of Hank Word, listed in the docket as the declaration of Harry Alan Word, Jr."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-yotta-discovery","record":{"id":"c-lit-yotta-discovery","kind":"fact","text":"In the January 22, 2026 order, Magistrate Judge Thomas S. Hixson denied Yotta's motion to compel documents that Evolve withheld under the bank examination privilege and as confidential supervisory information about the controls of its Open Banking Division, but granted Yotta three more hours to depose Evolve's corporate designee, finding that Evolve's counsel's 'many speaking objections and efforts to coach the witness disrupted the deposition'.","source_ids":["src-069"],"entity_ids":["evolve","yotta"],"qualification":"","response":"","outcome":""},"reading":"Fact: In the January 22, 2026 order, Magistrate Judge Thomas S. Hixson denied Yotta's motion to compel documents that Evolve withheld under the bank examination privilege and as confidential supervisory information about the controls of its Open Banking Division, but granted Yotta three more hours to depose Evolve's corporate designee, finding that Evolve's counsel's 'many speaking objections and efforts to coach the witness disrupted the deposition'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-yotta-testimony","record":{"id":"c-lit-yotta-testimony","kind":"attributed","text":"A fintech industry newsletter reported in January 2026 that, according to Yotta's portion of a joint discovery letter, former Evolve chief technology officer W. Christopher Staab testified in December 2025 that the gap between the bank's funds and Synapse's ledgers likely led Evolve to fail to obtain the necessary deposit insurance for the larger amount it should have held; that former Open Banking president Hank Word invoked his Fifth Amendment right when asked whether Yotta users' funds were FDIC-insured; and that a bank witness said Evolve 'does not know how Ankura calculated the amount that each user was entitled to'.","source_ids":["src-103"],"entity_ids":["evolve","yotta","christopher-staab","hank-word","ankura"],"qualification":"Yotta's characterisation of deposition testimony in a discovery filing, as reported by a newsletter; the transcripts are not in the retained record, and no court has made findings on these points. Invoking the privilege against self-incrimination is not itself evidence of wrongdoing.","response":"In its portion of the filing, Evolve cited its privacy obligations under the Gramm-Leach-Bliley Act for refusing to turn over documents containing end users' personal information; Word did not respond to the newsletter's request for comment.","outcome":""},"reading":"Attributed: A fintech industry newsletter reported in January 2026 that, according to Yotta's portion of a joint discovery letter, former Evolve chief technology officer W. Christopher Staab testified in December 2025 that the gap between the bank's funds and Synapse's ledgers likely led Evolve to fail to obtain the necessary deposit insurance for the larger amount it should have held; that former Open Banking president Hank Word invoked his Fifth Amendment right when asked whether Yotta users' funds were FDIC-insured; and that a bank witness said Evolve 'does not know how Ankura calculated the amount that each user was entitled to'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-colorado","record":{"id":"c-lit-colorado","kind":"fact","text":"End users of Synapse-linked fintechs, mainly Yotta and Juno customers, filed a proposed class action in federal court in Colorado in November 2024 against American Bank, AMG National Trust, Lineage Bank, Evolve Bank & Trust and Evolve Bancorp. In the consolidated case (D. Colo. No. 24-cv-03259 with five related cases), Magistrate Judge N. Reid Neureiter on April 16, 2026 extended the schedule: fact and class discovery closes January 15, 2027, the class certification motion is due March 17, 2027 and dispositive motions September 29, 2027.","source_ids":["src-104","src-113"],"entity_ids":["evolve","evolve-bancorp","amg-national-trust","lineage-bank","american-bank"],"qualification":"The plaintiffs allege the banks failed to safeguard customer funds; there is no ruling on the merits in the retained record.","response":"","outcome":"","adverse_subject_ids":["evolve","evolve-bancorp"]},"reading":"Fact: End users of Synapse-linked fintechs, mainly Yotta and Juno customers, filed a proposed class action in federal court in Colorado in November 2024 against American Bank, AMG National Trust, Lineage Bank, Evolve Bank & Trust and Evolve Bancorp. In the consolidated case (D. Colo. No. 24-cv-03259 with five related cases), Magistrate Judge N. Reid Neureiter on April 16, 2026 extended the schedule: fact and class discovery closes January 15, 2027, the class certification motion is due March 17, 2027 and dispositive motions September 29, 2027."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-colorado-claims","record":{"id":"c-lit-colorado-claims","kind":"attributed","text":"According to a banking trade publication's account of the Colorado complaint, about $85 million belonging to about 100,000 customers could not be traced after the Synapse bankruptcy because of ledger irregularities, most end-user funds had been held in omnibus FBO accounts and the rest in demand-deposit accounts at the four banks, and the banks kept no copy of the ledger and had no contingency plan. The court has recorded the plaintiffs' statement that the case requires tracing hundreds of millions of dollars through pooled FBO accounts and more than ten terabytes of data, and that neither the trustee nor any defendant has completed a full reconciliation.","source_ids":["src-104","src-113","src-109"],"entity_ids":["evolve","amg-national-trust","lineage-bank","american-bank","synapse"],"qualification":"Plaintiffs' allegations and representations, not findings.","response":"AMG has moved for summary judgment, arguing that it distributed all or almost all end-user funds according to Synapse Brokerage's instructions and the final trial balance, owed no duty to the plaintiffs and holds none of their money; the plaintiffs dispute its data and method.","outcome":"The consolidated case is pending: the court's April 16, 2026 schedule closes fact and class discovery on January 15, 2027 and sets March 17, 2027 for the class-certification motion; the separate California case was transferred to Colorado on October 16, 2025."},"reading":"Attributed: According to a banking trade publication's account of the Colorado complaint, about $85 million belonging to about 100,000 customers could not be traced after the Synapse bankruptcy because of ledger irregularities, most end-user funds had been held in omnibus FBO accounts and the rest in demand-deposit accounts at the four banks, and the banks kept no copy of the ledger and had no contingency plan. The court has recorded the plaintiffs' statement that the case requires tracing hundreds of millions of dollars through pooled FBO accounts and more than ten terabytes of data, and that neither the trustee nor any defendant has completed a full reconciliation."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-california","record":{"id":"c-lit-california","kind":"fact","text":"A separate proposed class action filed on November 27, 2024 in the Central District of California (No. 2:24-cv-10317, Judge George H. Wu) against Lineage Bank, American Bank, AMG National Trust, Evolve Bancorp, Inc. and Evolve Bank and Trust was transferred on October 16, 2025 to the District of Colorado under the first-to-file rule, after hearings on motions to dismiss by Lineage, Evolve Bank & Trust and Evolve Bancorp; the plaintiff's request to add Synapse, Synapse Brokerage, Mark Paverman and Jeffrey Stanley as defendants was left to that court.","source_ids":["src-109"],"entity_ids":["evolve","evolve-bancorp","lineage-bank","american-bank","amg-national-trust"],"qualification":"","response":"","outcome":""},"reading":"Fact: A separate proposed class action filed on November 27, 2024 in the Central District of California (No. 2:24-cv-10317, Judge George H. Wu) against Lineage Bank, American Bank, AMG National Trust, Evolve Bancorp, Inc. and Evolve Bank and Trust was transferred on October 16, 2025 to the District of Colorado under the first-to-file rule, after hearings on motions to dismiss by Lineage, Evolve Bank & Trust and Evolve Bancorp; the plaintiff's request to add Synapse, Synapse Brokerage, Mark Paverman and Jeffrey Stanley as defendants was left to that court."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-tennessee","record":{"id":"c-lit-tennessee","kind":"attributed","text":"On April 4, 2025 a Yotta customer filed a proposed class action in the Western District of Tennessee against Evolve Bank & Trust, Evolve Bancorp and Lineage Bank, alleging negligent oversight and mishandling of funds after the Synapse collapse and seeking restitution, damages and a constructive trust; the complaint says his account showed $4,420.50 and he received $3.46 through the reconciliation. His lawyer said the case was filed because Lineage had challenged jurisdiction in the Colorado case.","source_ids":["src-110"],"entity_ids":["evolve","evolve-bancorp","lineage-bank","yotta"],"qualification":"Allegations reported by a banking trade publication; no ruling appears in the retained record.","response":"Evolve declined to comment on the active litigation.","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Attributed: On April 4, 2025 a Yotta customer filed a proposed class action in the Western District of Tennessee against Evolve Bank & Trust, Evolve Bancorp and Lineage Bank, alleging negligent oversight and mishandling of funds after the Synapse collapse and seeking restitution, damages and a constructive trust; the complaint says his account showed $4,420.50 and he received $3.46 through the reconciliation. His lawyer said the case was filed because Lineage had challenged jurisdiction in the Colorado case."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-finra-complaint","record":{"id":"c-lit-finra-complaint","kind":"fact","text":"On August 28, 2025 FINRA's Department of Enforcement filed a disciplinary complaint (No. 2023080111701) against two former officers of Synapse Brokerage LLC: Jeffrey Alan Stanley, accused of failing to supervise the firm's cash management program, approving the opening of hundreds of thousands of accounts and transfers of customer funds without adequate authorisation, and failing to detect the ledger reallocation of tens of millions of dollars to a bank without customer authorisation; and Mark Elliot Paverman, accused of record-keeping failures.","source_ids":["src-027","src-068","src-032"],"entity_ids":["finra","jeffrey-stanley","mark-paverman","synapse-brokerage"],"qualification":"","response":"","outcome":""},"reading":"Fact: On August 28, 2025 FINRA's Department of Enforcement filed a disciplinary complaint (No. 2023080111701) against two former officers of Synapse Brokerage LLC: Jeffrey Alan Stanley, accused of failing to supervise the firm's cash management program, approving the opening of hundreds of thousands of accounts and transfers of customer funds without adequate authorisation, and failing to detect the ledger reallocation of tens of millions of dollars to a bank without customer authorisation; and Mark Elliot Paverman, accused of record-keeping failures."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-finra-paverman","record":{"id":"c-lit-finra-paverman","kind":"fact","text":"Mark E. Paverman settled on January 28, 2026 without admitting or denying the allegations. He consented to findings that Synapse Brokerage, acting through him, failed to preserve required electronic communications and that he falsely certified to FINRA that the firm itself had contracted with a record-retention vendor, when the contract was with its parent; he was fined $20,000 and suspended from any principal capacity for 12 months from February 17, 2026. His BrokerCheck record shows him registered with Synapse Brokerage from January 2021 to January 2025.","source_ids":["src-068"],"entity_ids":["mark-paverman","synapse-brokerage","finra"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["mark-paverman"]},"reading":"Fact: Mark E. Paverman settled on January 28, 2026 without admitting or denying the allegations. He consented to findings that Synapse Brokerage, acting through him, failed to preserve required electronic communications and that he falsely certified to FINRA that the firm itself had contracted with a record-retention vendor, when the contract was with its parent; he was fined $20,000 and suspended from any principal capacity for 12 months from February 17, 2026. His BrokerCheck record shows him registered with Synapse Brokerage from January 2021 to January 2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-finra-stanley","record":{"id":"c-lit-finra-stanley","kind":"fact","text":"Jeffrey A. Stanley settled on May 22, 2026 without admitting or denying the allegations. He consented to findings that from September 2023 to May 2024, when he controlled Synapse Brokerage's cash management program, the firm lacked a reasonable supervisory system, opened accounts and moved customer funds without adequate authorisation, let a non-FINRA member keep the customer ledger, and failed to investigate red flags of substantial discrepancies between that ledger and third-party banks' ledgers. He was suspended in all capacities for four months and from principal capacities for 12 months; FINRA imposed no monetary sanction in light of his financial status. BrokerCheck shows his registration with Synapse Brokerage from February 2023 to June 2024.","source_ids":["src-078"],"entity_ids":["jeffrey-stanley","synapse-brokerage","finra"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["jeffrey-stanley"]},"reading":"Fact: Jeffrey A. Stanley settled on May 22, 2026 without admitting or denying the allegations. He consented to findings that from September 2023 to May 2024, when he controlled Synapse Brokerage's cash management program, the firm lacked a reasonable supervisory system, opened accounts and moved customer funds without adequate authorisation, let a non-FINRA member keep the customer ledger, and failed to investigate red flags of substantial discrepancies between that ledger and third-party banks' ledgers. He was suspended in all capacities for four months and from principal capacities for 12 months; FINRA imposed no monetary sanction in light of his financial status. BrokerCheck shows his registration with Synapse Brokerage from February 2023 to June 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-grand-jury","record":{"id":"c-lit-grand-jury","kind":"attributed","text":"A business magazine reported in March 2025 that a court filing in late January had revealed that the U.S. Attorney's Office for the Southern District of New York had convened a grand jury in a criminal investigation into Synapse dating back to at least October 2024, subpoenaing Synapse's former corporate controller and examining possible violations including accounting and wire fraud; according to people familiar with the matter, prosecutors had asked about the shortfall and Synapse's relationship with Evolve.","source_ids":["src-096"],"entity_ids":["synapse","evolve","sankaet-pathak"],"qualification":"The investigation concerns Synapse; no charges against any person or against Evolve appear in the retained record.","response":"Pathak told a business magazine that prosecutors had not contacted him.","outcome":""},"reading":"Attributed: A business magazine reported in March 2025 that a court filing in late January had revealed that the U.S. Attorney's Office for the Southern District of New York had convened a grand jury in a criminal investigation into Synapse dating back to at least October 2024, subpoenaing Synapse's former corporate controller and examining possible violations including accounting and wire fraud; according to people familiar with the matter, prosecutors had asked about the shortfall and Synapse's relationship with Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-dfpi-yotta","record":{"id":"c-lit-dfpi-yotta","kind":"fact","text":"On May 15, 2026 California's Department of Financial Protection and Innovation entered a consent order with Yotta Technologies, Inc., a Delaware corporation based in San Francisco whose co-founder and former chief executive Adam Moelis signed for it. The order finds that Yotta worked with Synapse, which provided a 'banking as a service' platform to fintech companies, that it advertised savings as FDIC-insured 'through our partner bank Evolve Bank & Trust', that its California customers held Evolve routing and account numbers from at least 2020, and that after the Synapse bankruptcy at least 18,155 California customers lost access to at least twenty-eight million dollars. Yotta agreed to a desist-and-refrain order and a $1,000,000 penalty payable in instalments, with a $48,000,000 penalty available if it defaults.","source_ids":["src-037","src-052"],"entity_ids":["dfpi","yotta","adam-moelis","evolve","synapse"],"qualification":"The order concerns Yotta's conduct; Evolve is not a party to it.","response":"","outcome":"","adverse_subject_ids":["yotta"]},"reading":"Fact: On May 15, 2026 California's Department of Financial Protection and Innovation entered a consent order with Yotta Technologies, Inc., a Delaware corporation based in San Francisco whose co-founder and former chief executive Adam Moelis signed for it. The order finds that Yotta worked with Synapse, which provided a 'banking as a service' platform to fintech companies, that it advertised savings as FDIC-insured 'through our partner bank Evolve Bank & Trust', that its California customers held Evolve routing and account numbers from at least 2020, and that after the Synapse bankruptcy at least 18,155 California customers lost access to at least twenty-eight million dollars. Yotta agreed to a desist-and-refrain order and a $1,000,000 penalty payable in instalments, with a $48,000,000 penalty available if it defaults."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-dave","record":{"id":"c-lit-dave","kind":"fact","text":"Dave Inc. reports in its 2025 annual report that on April 1, 2025 a putative class of its customers sued Dave, Inc. and Evolve Bank & Trust in Los Angeles County Superior Court, alleging violations of the Military Lending Act and the Truth in Lending Act (a Georgia Payday Loan Act claim was added later). The case was removed to the Central District of California (No. 2:25-cv-04029), where on December 12, 2025 the court denied Dave's motions to dismiss and to compel arbitration; on December 26, 2025 Dave and Evolve jointly appealed to the Ninth Circuit and the district court stayed proceedings.","source_ids":["src-041","src-094"],"entity_ids":["dave","evolve"],"qualification":"Plaintiffs' allegations; no ruling on the merits.","response":"","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: Dave Inc. reports in its 2025 annual report that on April 1, 2025 a putative class of its customers sued Dave, Inc. and Evolve Bank & Trust in Los Angeles County Superior Court, alleging violations of the Military Lending Act and the Truth in Lending Act (a Georgia Payday Loan Act claim was added later). The case was removed to the Central District of California (No. 2:25-cv-04029), where on December 12, 2025 the court denied Dave's motions to dismiss and to compel arbitration; on December 26, 2025 Dave and Evolve jointly appealed to the Ninth Circuit and the district court stayed proceedings."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-lit-branch-cfpb","record":{"id":"c-lit-branch-cfpb","kind":"fact","text":"On December 23, 2024 the CFPB sued Walmart Inc. and Branch Messenger, Inc. in the District of Minnesota (No. 24-cv-4610), alleging that they opened Branch Accounts, which include a deposit account at Evolve Bank & Trust, for Walmart's Spark delivery drivers without informed consent, paid their wages into them and made deceptive statements about the accounts. Evolve is not a defendant.","source_ids":["src-067"],"entity_ids":["cfpb","branch","evolve"],"qualification":"Allegations in the CFPB's complaint.","response":"","outcome":"","adverse_subject_ids":["branch"]},"reading":"Fact: On December 23, 2024 the CFPB sued Walmart Inc. and Branch Messenger, Inc. in the District of Minnesota (No. 24-cv-4610), alleging that they opened Branch Accounts, which include a deposit account at Evolve Bank & Trust, for Walmart's Spark delivery drivers without informed consent, paid their wages into them and made deceptive statements about the accounts. Evolve is not a defendant."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-origin","record":{"id":"c-baas-origin","kind":"fact","text":"Evolve started its Open Banking business in 2017, offering fintech partners application-programming-interface (API) banking that let them build Evolve's banking services into their own platforms, later adding payment processing, compliance management and lending services, according to the bank's own history. An online encyclopedia describes the Open Banking division as a Banking-as-a-Service unit and names Branch, Marqeta, Mercury and Stripe among the fintechs for which Evolve is the partner bank.","source_ids":["src-012","src-004"],"entity_ids":["evolve","branch","marqeta","mercury","stripe"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve started its Open Banking business in 2017, offering fintech partners application-programming-interface (API) banking that let them build Evolve's banking services into their own platforms, later adding payment processing, compliance management and lending services, according to the bank's own history. An online encyclopedia describes the Open Banking division as a Banking-as-a-Service unit and names Branch, Marqeta, Mercury and Stripe among the fintechs for which Evolve is the partner bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-vaccounts","record":{"id":"c-baas-vaccounts","kind":"fact","text":"The bank's 2024 Investor Relations kit says fintech apps can issue 'vAccounts' to users, with the fintech keeping the relationship with the end user while Evolve holds the funds in its 'stored value ecosystem'. The 2023 kit describes an omnibus product as a pooled business account in which a business manages its users' funds in aggregate, alongside primary accounts that hold the funds securing programmes and daily money flows. The 2024 kit gives the Open Banking business principal membership of Visa and Mastercard and cites $8 billion in total bank and custodial assets and $104 billion in annual processed volume.","source_ids":["src-005","src-020"],"entity_ids":["evolve","visa","mastercard"],"qualification":"The asset and volume figures are the bank's own marketing figures and are undated in the kit; custodial assets are not balance-sheet assets.","response":"","outcome":""},"reading":"Fact: The bank's 2024 Investor Relations kit says fintech apps can issue 'vAccounts' to users, with the fintech keeping the relationship with the end user while Evolve holds the funds in its 'stored value ecosystem'. The 2023 kit describes an omnibus product as a pooled business account in which a business manages its users' funds in aggregate, alongside primary accounts that hold the funds securing programmes and daily money flows. The 2024 kit gives the Open Banking business principal membership of Visa and Mastercard and cites $8 billion in total bank and custodial assets and $104 billion in annual processed volume."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-sub-deposit","record":{"id":"c-baas-sub-deposit","kind":"fact","text":"Evolve's customer account terms used by partner platforms allow the bank to move customers' money onward. The agreement published by Sila directs the bank, as the customer's agent, to place funds at its discretion in a deposit or omnibus custody 'Sub-Deposit Account' in the bank's name in its Trust Department or at other insured banks, with ownership recorded only by book entry in the bank's records. The terms published by Dwolla say that when funds are placed with another insured bank, that bank's records are in Evolve's name as agent or custodian, that customers receive no written confirmation, that coverage is the same as if the funds stayed at Evolve, and that accounts are opened at the bank's Tennessee branch and governed by Tennessee and federal law.","source_ids":["src-045","src-085"],"entity_ids":["evolve","sila","dwolla"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve's customer account terms used by partner platforms allow the bank to move customers' money onward. The agreement published by Sila directs the bank, as the customer's agent, to place funds at its discretion in a deposit or omnibus custody 'Sub-Deposit Account' in the bank's name in its Trust Department or at other insured banks, with ownership recorded only by book entry in the bank's records. The terms published by Dwolla say that when funds are placed with another insured bank, that bank's records are in Evolve's name as agent or custodian, that customers receive no written confirmation, that coverage is the same as if the funds stayed at Evolve, and that accounts are opened at the bank's Tennessee branch and governed by Tennessee and federal law."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-b9-custodial","record":{"id":"c-baas-b9-custodial","kind":"fact","text":"Under the Evolve customer account and cardholder agreement effective March 27, 2026 for customers of B9, Inc., which provides access to the accounts through its app, customers take part in a 'Bank Deposit Custodial Program' in which Evolve, as agent and custodian, opens sub-deposit accounts at program banks; those accounts are solely obligations of the program banks and not of Evolve or B9.","source_ids":["src-061"],"entity_ids":["evolve","b9"],"qualification":"","response":"","outcome":""},"reading":"Fact: Under the Evolve customer account and cardholder agreement effective March 27, 2026 for customers of B9, Inc., which provides access to the accounts through its app, customers take part in a 'Bank Deposit Custodial Program' in which Evolve, as agent and custodian, opens sub-deposit accounts at program banks; those accounts are solely obligations of the program banks and not of Evolve or B9."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-melio-fbo","record":{"id":"c-baas-melio-fbo","kind":"fact","text":"Melio's 2023 terms of service list Evolve Bank & Trust among its bank providers, with JPMorgan Chase Bank and Silicon Valley Bank, and make Evolve a party for payors in Texas and Vermont. Melio uses master accounts at each bank, held in the bank's name and titled for the benefit of Melio's customers, and instructs the banks on moving those funds.","source_ids":["src-073"],"entity_ids":["evolve","melio"],"qualification":"","response":"","outcome":""},"reading":"Fact: Melio's 2023 terms of service list Evolve Bank & Trust among its bank providers, with JPMorgan Chase Bank and Silicon Valley Bank, and make Evolve a party for payors in Texas and Vermont. Melio uses master accounts at each bank, held in the bank's name and titled for the benefit of Melio's customers, and instructs the banks on moving those funds."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-dave-agreement","record":{"id":"c-baas-dave-agreement","kind":"fact","text":"Dave Inc., a Delaware company listed on Nasdaq, reports in its 2025 annual report a Bank Services Agreement with Evolve dated July 13, 2020 (amended August 8, 2024 with Dave Operating LLC) under which Evolve issues and maintains the deposit accounts and sponsors debit network and ACH access, while Dave runs customer service and the technology platform and keeps the ledger of funds in each account needed for pass-through FDIC insurance; a separate Debit Card Issuing Agreement of July 13, 2020 covers Dave's debit cards. Customer funds are held by the partner banks, not by Dave.","source_ids":["src-041"],"entity_ids":["dave","evolve","dave-operating"],"qualification":"","response":"","outcome":""},"reading":"Fact: Dave Inc., a Delaware company listed on Nasdaq, reports in its 2025 annual report a Bank Services Agreement with Evolve dated July 13, 2020 (amended August 8, 2024 with Dave Operating LLC) under which Evolve issues and maintains the deposit accounts and sponsors debit network and ACH access, while Dave runs customer service and the technology platform and keeps the ledger of funds in each account needed for pass-through FDIC insurance; a separate Debit Card Issuing Agreement of July 13, 2020 covers Dave's debit cards. Customer funds are held by the partner banks, not by Dave."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-dave-exit","record":{"id":"c-baas-dave-exit","kind":"fact","text":"Dave's 2025 annual report says that all new members are now opened at Coastal Community Bank, that Dave runs concurrent programmes with Coastal and Evolve, that the substantial majority of members' accounts were still with Evolve and Dave relied on Evolve for most of its ExtraCash advances, and that it expected to substantially finish moving existing members to Coastal by the end of 2026.","source_ids":["src-041"],"entity_ids":["dave","evolve","coastal-community-bank"],"qualification":"","response":"","outcome":""},"reading":"Fact: Dave's 2025 annual report says that all new members are now opened at Coastal Community Bank, that Dave runs concurrent programmes with Coastal and Evolve, that the substantial majority of members' accounts were still with Evolve and Dave relied on Evolve for most of its ExtraCash advances, and that it expected to substantially finish moving existing members to Coastal by the end of 2026."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-affirm","record":{"id":"c-baas-affirm","kind":"fact","text":"Affirm Holdings, Inc. states in its annual report for the year to June 30, 2025 that Evolve Bank & Trust is the single issuing bank for the Affirm Card and that its loan program agreement with Evolve had an initial two-year term that expired in 2023 and renews automatically each year. Affirm, which reincorporated from Delaware to Nevada on July 1, 2025, cites the Evolve cybersecurity incident reported in June 2024 as an example of third-party risk.","source_ids":["src-042"],"entity_ids":["affirm","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Affirm Holdings, Inc. states in its annual report for the year to June 30, 2025 that Evolve Bank & Trust is the single issuing bank for the Affirm Card and that its loan program agreement with Evolve had an initial two-year term that expired in 2023 and renews automatically each year. Affirm, which reincorporated from Delaware to Nevada on July 1, 2025, cites the Evolve cybersecurity incident reported in June 2024 as an example of third-party risk."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-marqeta","record":{"id":"c-baas-marqeta","kind":"fact","text":"Evolve announced a partnership with Marqeta in its June 2022 shareholder letter; Marqeta's announcement quoted Hank Word, then president of the Open Banking division, and said Evolve would support its full range of program management services for U.S. card programmes, including BIN management, compliance reporting and settlement. Marqeta's 2025 annual report names Sutton Bank as the issuing bank for 64% to 76% of its processing volume in 2023 to 2025 and does not name Evolve.","source_ids":["src-034","src-046","src-051"],"entity_ids":["evolve","marqeta","hank-word"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve announced a partnership with Marqeta in its June 2022 shareholder letter; Marqeta's announcement quoted Hank Word, then president of the Open Banking division, and said Evolve would support its full range of program management services for U.S. card programmes, including BIN management, compliance reporting and settlement. Marqeta's 2025 annual report names Sutton Bank as the issuing bank for 64% to 76% of its processing volume in 2023 to 2025 and does not name Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-stripe-arc","record":{"id":"c-baas-stripe-arc","kind":"fact","text":"Stripe's guide to building a fintech states that Stripe Treasury is provided by Stripe Payments Company, a licensed money transmitter, with funds held at Evolve Bank & Trust and Goldman Sachs Bank USA, and quotes the fintech Arc as placing start-ups' funds in a virtual treasury account held by Evolve Bank. California's regulator lists Stripe Payments Company and Airwallex US, LLC as licensed money transmitters with no posted enforcement actions.","source_ids":["src-076","src-092","src-091"],"entity_ids":["stripe","evolve","arc","airwallex"],"qualification":"","response":"","outcome":""},"reading":"Fact: Stripe's guide to building a fintech states that Stripe Treasury is provided by Stripe Payments Company, a licensed money transmitter, with funds held at Evolve Bank & Trust and Goldman Sachs Bank USA, and quotes the fintech Arc as placing start-ups' funds in a virtual treasury account held by Evolve Bank. California's regulator lists Stripe Payments Company and Airwallex US, LLC as licensed money transmitters with no posted enforcement actions."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-airwallex","record":{"id":"c-baas-airwallex","kind":"fact","text":"Airwallex's U.S. service agreement with Airwallex US, LLC provides that domestic payment services may be provided directly by Airwallex or as a bank service by Evolve Bank & Trust under Evolve's own customer terms, with Airwallex supplying the technology.","source_ids":["src-071"],"entity_ids":["airwallex","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Airwallex's U.S. service agreement with Airwallex US, LLC provides that domestic payment services may be provided directly by Airwallex or as a bank service by Evolve Bank & Trust under Evolve's own customer terms, with Airwallex supplying the technology."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-earnin","record":{"id":"c-baas-earnin","kind":"fact","text":"EarnIn's Early Pay product requires users to open a deposit account with its partner bank, Evolve Bank & Trust or Lead Bank, and says the $2.99 fee for faster transfer of a direct deposit is charged by that partner bank.","source_ids":["src-074"],"entity_ids":["earnin","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: EarnIn's Early Pay product requires users to open a deposit account with its partner bank, Evolve Bank & Trust or Lead Bank, and says the $2.99 fee for faster transfer of a direct deposit is charged by that partner bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-branch","record":{"id":"c-baas-branch","kind":"fact","text":"Branch Messenger, Inc., a Delaware company in Golden Valley, Minnesota, has since January 2020 offered a Branch Account that includes a deposit account at Evolve Bank & Trust, accessed through Branch's app and debit card.","source_ids":["src-090","src-067"],"entity_ids":["branch","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Branch Messenger, Inc., a Delaware company in Golden Valley, Minnesota, has since January 2020 offered a Branch Account that includes a deposit account at Evolve Bank & Trust, accessed through Branch's app and debit card."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-usio","record":{"id":"c-baas-usio","kind":"fact","text":"The payments company Usio, Inc. reports that after its previous sponsor bank ended its gateway provider's relationship in January 2018, it secured a relationship with Evolve Bank & Trust to resume processing PINless debit transactions, and later obtained sponsorship from TransPecos Bank in 2023.","source_ids":["src-049"],"entity_ids":["usio","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The payments company Usio, Inc. reports that after its previous sponsor bank ended its gateway provider's relationship in January 2018, it secured a relationship with Evolve Bank & Trust to resume processing PINless debit transactions, and later obtained sponsorship from TransPecos Bank in 2023."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-dwolla","record":{"id":"c-baas-dwolla","kind":"fact","text":"Dwolla publishes the Evolve Bank & Trust personal account terms (last updated August 1, 2021) as a legal document for its clients' virtual account numbers, with error-resolution requests directed to Dwolla in Des Moines, Iowa.","source_ids":["src-085"],"entity_ids":["dwolla","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: Dwolla publishes the Evolve Bank & Trust personal account terms (last updated August 1, 2021) as a legal document for its clients' virtual account numbers, with error-resolution requests directed to Dwolla in Des Moines, Iowa."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-partners-2023","record":{"id":"c-baas-partners-2023","kind":"fact","text":"The 'Who we power' page of the bank's 2023 Investor Relations kit shows the logos of Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold.","source_ids":["src-020"],"entity_ids":["evolve","branch","earnin","melio","prizepool","sila","stripe","uphold"],"qualification":"Logo text recognised from an image; the kit does not describe the services provided to each.","response":"","outcome":""},"reading":"Fact: The 'Who we power' page of the bank's 2023 Investor Relations kit shows the logos of Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-partners-2024","record":{"id":"c-baas-partners-2024","kind":"fact","text":"The corresponding page of the 2024 kit shows the logos of Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio.","source_ids":["src-005"],"entity_ids":["evolve","affirm","airwallex","bond","branch","dave","marqeta","melio"],"qualification":"Logo text recognised from an image.","response":"","outcome":""},"reading":"Fact: The corresponding page of the 2024 kit shows the logos of Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-partners-site","record":{"id":"c-baas-partners-site","kind":"fact","text":"The Open Banking partnerships page of the bank's website, in the copy retained for this dossier, lists Airwallex, Affirm, Branch, EarnIn, Flute, Luqra, Marqeta, Mastercard, Melio, Netevia, Rain, Split Pay, Step, TabaPay, Visa and VIVA Finance as partners.","source_ids":["src-043"],"entity_ids":["evolve","airwallex","affirm","branch","earnin","flute","luqra","marqeta","mastercard","melio","netevia","rain","split-pay","step","tabapay","visa","viva-finance"],"qualification":"The bank's own list; it does not distinguish card networks, programme managers and fintech programmes.","response":"","outcome":""},"reading":"Fact: The Open Banking partnerships page of the bank's website, in the copy retained for this dossier, lists Airwallex, Affirm, Branch, EarnIn, Flute, Luqra, Marqeta, Mastercard, Melio, Netevia, Rain, Split Pay, Step, TabaPay, Visa and VIVA Finance as partners."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-coinstar","record":{"id":"c-baas-coinstar","kind":"fact","text":"The bank's news page, in its retained copy, lists an item titled 'Coinstar Expands Transfer to Account Service with TabaPay and Evolve Bank & Trust'.","source_ids":["src-114"],"entity_ids":["evolve","coinstar","tabapay"],"qualification":"","response":"","outcome":""},"reading":"Fact: The bank's news page, in its retained copy, lists an item titled 'Coinstar Expands Transfer to Account Service with TabaPay and Evolve Bank & Trust'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-solo-branch","record":{"id":"c-baas-solo-branch","kind":"attributed","text":"The April 2025 senators' letter states that, besides Synapse, Evolve partnered with SoLo Funds and Branch, two fintechs sued by the CFPB for predatory lending and unlawful deposit account practices respectively.","source_ids":["src-031"],"entity_ids":["evolve","solo-funds","branch","cfpb"],"qualification":"The senators' characterisation; the CFPB case against SoLo Funds is not in the retained record.","response":"","outcome":""},"reading":"Attributed: The April 2025 senators' letter states that, besides Synapse, Evolve partnered with SoLo Funds and Branch, two fintechs sued by the CFPB for predatory lending and unlawful deposit account practices respectively."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-departures","record":{"id":"c-baas-departures","kind":"attributed","text":"A fintech industry newsletter reported in February 2026 that major fintech programmes, including Mercury and Dave, had left Evolve, cutting its deposit and referral fee revenue by 66%, and named the teen banking app Step, the cash-advance app B9 and the middleware platform Mbanq among partners still working with the bank. An online encyclopedia records that Mercury announced in March 2025 that it would move its customers from Evolve to Column N.A. and Choice Financial Group by the end of 2025.","source_ids":["src-035","src-050","src-096"],"entity_ids":["evolve","mercury","dave","step","b9","mbanq"],"qualification":"Newsletter reading of the bank's call report and of partner announcements.","response":"An Evolve spokesperson told a business magazine in March 2025 that the bank remained focused on strengthening its existing relationships and exploring new opportunities with established fintechs.","outcome":""},"reading":"Attributed: A fintech industry newsletter reported in February 2026 that major fintech programmes, including Mercury and Dave, had left Evolve, cutting its deposit and referral fee revenue by 66%, and named the teen banking app Step, the cash-advance app B9 and the middleware platform Mbanq among partners still working with the bank. An online encyclopedia records that Mercury announced in March 2025 that it would move its customers from Evolve to Column N.A. and Choice Financial Group by the end of 2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-baas-coastal","record":{"id":"c-baas-coastal","kind":"fact","text":"On April 29, 2026 Coastal Community Bank, a subsidiary of Coastal Financial Corporation, entered into a non-binding term sheet with Evolve Bank & Trust under which it might acquire the assets and deposits of a diverse set of Banking-as-a-Service programmes operated by Evolve, subject to due diligence, definitive agreements and regulatory approval.","source_ids":["src-028","src-119"],"entity_ids":["coastal-community-bank","evolve"],"qualification":"","response":"","outcome":"On Coastal's second-quarter earnings call on July 30, 2026, chief executive Eric Sprink said Coastal was no longer actively pursuing the acquisition, according to a market-news summary."},"reading":"Fact: On April 29, 2026 Coastal Community Bank, a subsidiary of Coastal Financial Corporation, entered into a non-binding term sheet with Evolve Bank & Trust under which it might acquire the assets and deposits of a diverse set of Banking-as-a-Service programmes operated by Evolve, subject to due diligence, definitive agreements and regulatory approval."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-attack","record":{"id":"c-brc-attack","kind":"fact","text":"According to the bank's substitute notice of data breach (version of August 27, 2024), Evolve found in late May 2024 that some systems were not working properly and then established that it was a ransomware attack by the criminal group LockBit, which appears to have gained access when an employee clicked a malicious link. The attackers downloaded customer information from databases and a file share during periods in February and May 2024 and encrypted some data; Evolve stopped the attack, saw no new unauthorised activity after May 31, 2024, reported the incident to law enforcement, refused to pay the ransom, and the stolen data was leaked. The bank said there was no evidence that customer funds were accessed.","source_ids":["src-044"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: According to the bank's substitute notice of data breach (version of August 27, 2024), Evolve found in late May 2024 that some systems were not working properly and then established that it was a ransomware attack by the criminal group LockBit, which appears to have gained access when an employee clicked a malicious link. The attackers downloaded customer information from databases and a file share during periods in February and May 2024 and encrypted some data; Evolve stopped the attack, saw no new unauthorised activity after May 31, 2024, reported the incident to law enforcement, refused to pay the ransom, and the stolen data was leaked. The bank said there was no evidence that customer funds were accessed."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-data","record":{"id":"c-brc-data","kind":"fact","text":"The bank's notice states that the affected data appeared to include names, Social Security numbers, Evolve account numbers, dates of birth and contact information of most of its personal, mortgage, trust and small-business banking customers and of customers of its Open Banking partners, debit card numbers for a small portion, and ACH transaction records with account numbers, routing numbers and names of payors and payees. Individual notifications began on July 8, 2024 with an offer of two years of credit monitoring and identity protection for U.S. residents.","source_ids":["src-044"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The bank's notice states that the affected data appeared to include names, Social Security numbers, Evolve account numbers, dates of birth and contact information of most of its personal, mortgage, trust and small-business banking customers and of customers of its Open Banking partners, debit card numbers for a small portion, and ACH transaction records with account numbers, routing numbers and names of payors and payees. Individual notifications began on July 8, 2024 with an offer of two years of credit monitoring and identity protection for U.S. residents."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-maine","record":{"id":"c-brc-maine","kind":"fact","text":"Evolve's breach notice to the Office of the Maine Attorney General, filed by its outside counsel, reports a hacking breach that occurred on February 9, 2024 and was discovered on May 29, 2024, affecting 7,640,112 people in total, 20,970 of them Maine residents, with notices sent on July 8, 2024 and 24 months of credit monitoring and identity protection offered.","source_ids":["src-082","src-081"],"entity_ids":["evolve"],"qualification":"The retained copy is an archived web copy of the state's breach-notice listing.","response":"","outcome":""},"reading":"Fact: Evolve's breach notice to the Office of the Maine Attorney General, filed by its outside counsel, reports a hacking breach that occurred on February 9, 2024 and was discovered on May 29, 2024, affecting 7,640,112 people in total, 20,970 of them Maine residents, with notices sent on July 8, 2024 and 24 months of credit monitoring and identity protection offered."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-partners","record":{"id":"c-brc-partners","kind":"fact","text":"Partner firms reported effects on their own customers: Dave Inc. states that the 2024 breach at its bank partner Evolve disclosed members' names, Social Security numbers, partner bank account numbers, dates of birth and contact information; an online encyclopedia records that Affirm, Mercury and Wise announced that their customers were affected, and that the breach exposed account numbers and balances of Mercury accounts. Affirm's annual report cites the incident as an example of third-party risk that could expose it to regulatory action and claims.","source_ids":["src-041","src-004","src-050","src-042"],"entity_ids":["evolve","dave","affirm","mercury","wise"],"qualification":"","response":"","outcome":""},"reading":"Fact: Partner firms reported effects on their own customers: Dave Inc. states that the 2024 breach at its bank partner Evolve disclosed members' names, Social Security numbers, partner bank account numbers, dates of birth and contact information; an online encyclopedia records that Affirm, Mercury and Wise announced that their customers were affected, and that the breach exposed account numbers and balances of Mercury accounts. Affirm's annual report cites the incident as an example of third-party risk that could expose it to regulatory action and claims."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-mdl","record":{"id":"c-brc-mdl","kind":"fact","text":"After multiple putative class actions were filed against Evolve and fintech partners, the Judicial Panel on Multidistrict Litigation created MDL No. 3127, In re: Evolve Bank & Trust Customer Data Security Breach Litigation, on October 4, 2024 and assigned it to Chief Judge Sheryl H. Lipman in the Western District of Tennessee (No. 2:24-md-03127), later transferring twelve more cases. The court docket lists Affirm Holdings, Inc., Affirm, Inc., Branch Messenger Inc, CapitalJ Inc and Yotta Technologies, Inc. as defendants alongside Evolve. A consolidated complaint filed on January 21, 2025 alleged negligence, breach of third-party-beneficiary contract, unjust enrichment and California statutory claims.","source_ids":["src-083","src-084"],"entity_ids":["evolve","affirm","branch","capitalj","yotta"],"qualification":"Allegations of the plaintiffs; the court has made no finding of liability.","response":"","outcome":"","adverse_subject_ids":["evolve"]},"reading":"Fact: After multiple putative class actions were filed against Evolve and fintech partners, the Judicial Panel on Multidistrict Litigation created MDL No. 3127, In re: Evolve Bank & Trust Customer Data Security Breach Litigation, on October 4, 2024 and assigned it to Chief Judge Sheryl H. Lipman in the Western District of Tennessee (No. 2:24-md-03127), later transferring twelve more cases. The court docket lists Affirm Holdings, Inc., Affirm, Inc., Branch Messenger Inc, CapitalJ Inc and Yotta Technologies, Inc. as defendants alongside Evolve. A consolidated complaint filed on January 21, 2025 alleged negligence, breach of third-party-beneficiary contract, unjust enrichment and California statutory claims."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-brc-settlement","record":{"id":"c-brc-settlement","kind":"fact","text":"After a mediation on January 31, 2025, the parties agreed to settle. The court-approved notice (filed April 1, 2025) offers class members, all people in the United States whose information was in the affected files, reimbursement of documented losses of up to $3,000 or a flat cash payment estimated at $20, plus credit monitoring, with Kroll Settlement Administration as administrator; class counsel could seek fees of up to one-third of the settlement fund, stated as $3,789,475.79. The court scheduled the final fairness hearing for November 14, 2025 and on November 13, 2025 denied a pro se objector's motions to halt final approval.","source_ids":["src-077","src-084","src-115"],"entity_ids":["evolve"],"qualification":"The notice does not state the fund total in the retained text; a class-action news site reported the settlement as $11.9 million. The outcome of the final hearing is not in the retained record.","response":"Evolve denies any wrongdoing, and the notice states that no court has determined that it did anything wrong.","outcome":""},"reading":"Fact: After a mediation on January 31, 2025, the parties agreed to settle. The court-approved notice (filed April 1, 2025) offers class members, all people in the United States whose information was in the affected files, reimbursement of documented losses of up to $3,000 or a flat cash payment estimated at $20, plus credit monitoring, with Kroll Settlement Administration as administrator; class counsel could seek fees of up to one-third of the settlement fund, stated as $3,789,475.79. The court scheduled the final fairness hearing for November 14, 2025 and on November 13, 2025 denied a pro se objector's motions to halt final approval."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-fdic-series","record":{"id":"c-fin-fdic-series","kind":"fact","text":"FDIC call-report data for Evolve Bank & Trust show year-end total assets and deposits (in thousands of dollars) of $451,290 and $373,643 in 2019, $691,611 and $514,782 in 2020, $788,114 and $639,128 in 2021, $1,747,013 and $1,541,644 in 2022, $1,431,947 and $989,260 in 2023, $1,812,062 and $1,331,043 in 2024, and $1,286,556 and $1,072,077 in 2025. Full-year net income was $4,697 in 2019, $10,992 in 2020, $12,954 in 2021, $25,536 in 2022, $24,671 in 2023 and $10,298 in 2024; 2025 ended with a net loss of $3,020.","source_ids":["src-117","src-118"],"entity_ids":["evolve","fdic"],"qualification":"Bank-only figures from the FDIC; they exclude the holding company.","response":"","outcome":""},"reading":"Fact: FDIC call-report data for Evolve Bank & Trust show year-end total assets and deposits (in thousands of dollars) of $451,290 and $373,643 in 2019, $691,611 and $514,782 in 2020, $788,114 and $639,128 in 2021, $1,747,013 and $1,541,644 in 2022, $1,431,947 and $989,260 in 2023, $1,812,062 and $1,331,043 in 2024, and $1,286,556 and $1,072,077 in 2025. Full-year net income was $4,697 in 2019, $10,992 in 2020, $12,954 in 2021, $25,536 in 2022, $24,671 in 2023 and $10,298 in 2024; 2025 ended with a net loss of $3,020."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-2025-capital","record":{"id":"c-fin-2025-capital","kind":"fact","text":"At December 31, 2025 the FDIC data show uninsured deposits of $411,913 thousand, total equity of $162,355 thousand and tier 1 capital of $158,346 thousand for the bank.","source_ids":["src-117"],"entity_ids":["evolve","fdic"],"qualification":"","response":"","outcome":""},"reading":"Fact: At December 31, 2025 the FDIC data show uninsured deposits of $411,913 thousand, total equity of $162,355 thousand and tier 1 capital of $158,346 thousand for the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-2026-h1","record":{"id":"c-fin-2026-h1","kind":"fact","text":"The FDIC institution record for June 30, 2026 shows total assets of $1,188,644 thousand, deposits of $980,920 thousand, equity of $161,376 thousand and a year-to-date net loss of $865 thousand.","source_ids":["src-001"],"entity_ids":["evolve","fdic"],"qualification":"","response":"","outcome":""},"reading":"Fact: The FDIC institution record for June 30, 2026 shows total assets of $1,188,644 thousand, deposits of $980,920 thousand, equity of $161,376 thousand and a year-to-date net loss of $865 thousand."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-asbd-assets","record":{"id":"c-fin-asbd-assets","kind":"fact","text":"The Arkansas regulator's reports give the bank's total assets as $34,778 thousand at June 30, 2006 and $1,459,376 thousand at June 30, 2025.","source_ids":["src-025","src-024"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The Arkansas regulator's reports give the bank's total assets as $34,778 thousand at June 30, 2006 and $1,459,376 thousand at June 30, 2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-growth-2019-2022","record":{"id":"c-fin-growth-2019-2022","kind":"fact","text":"The senators' April 2025 letter, citing the bank's call reports, notes that after it moved to the Banking-as-a-Service model the bank grew from $451 million in assets at the end of 2019 to $1.75 billion three years later.","source_ids":["src-031"],"entity_ids":["evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The senators' April 2025 letter, citing the bank's call reports, notes that after it moved to the Banking-as-a-Service model the bank grew from $451 million in assets at the end of 2019 to $1.75 billion three years later."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-q1-2022","record":{"id":"c-fin-q1-2022","kind":"fact","text":"Evolve Bancorp's shareholder letter of June 6, 2022, signed by B. Scot Lenoir as chairman, reported consolidated total assets of $777.7 million and deposits of $592.3 million at March 31, 2022 and $10.5 million of subordinated notes issued by the holding company in March 2022. Open Banking Division non-interest income rose 83.8% to $9.3 million in the first quarter of 2022, from wire, ACH, card issuing and acquiring and other payment services, and the division processed 113.2 million transactions against 62.8 million a year earlier.","source_ids":["src-034"],"entity_ids":["evolve-bancorp","evolve","scot-lenoir"],"qualification":"","response":"","outcome":""},"reading":"Fact: Evolve Bancorp's shareholder letter of June 6, 2022, signed by B. Scot Lenoir as chairman, reported consolidated total assets of $777.7 million and deposits of $592.3 million at March 31, 2022 and $10.5 million of subordinated notes issued by the holding company in March 2022. Open Banking Division non-interest income rose 83.8% to $9.3 million in the first quarter of 2022, from wire, ACH, card issuing and acquiring and other payment services, and the division processed 113.2 million transactions against 62.8 million a year earlier."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-h1-2025","record":{"id":"c-fin-h1-2025","kind":"fact","text":"A regional business publication reported on October 27, 2025 that Evolve Bank & Trust lost $8.76 million in the first six months of 2025 and that chief executive Bob Hartheimer, who had taken over that summer, said losses would continue into the next year while the bank installed guardrails against a repeat of the problems behind the federal enforcement actions; the paper described the bank as having five Arkansas branches.","source_ids":["src-112"],"entity_ids":["evolve","robert-hartheimer"],"qualification":"","response":"","outcome":""},"reading":"Fact: A regional business publication reported on October 27, 2025 that Evolve Bank & Trust lost $8.76 million in the first six months of 2025 and that chief executive Bob Hartheimer, who had taken over that summer, said losses would continue into the next year while the bank installed guardrails against a repeat of the problems behind the federal enforcement actions; the paper described the bank as having five Arkansas branches."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-2025-trend","record":{"id":"c-fin-2025-trend","kind":"attributed","text":"A fintech industry newsletter, reading the bank's call report for the fourth quarter of 2025, reported a year-to-date net loss of $14 million at the end of September 2025 narrowing to $3 million for the year, helped by lower (technically negative) legal, consulting and advisory fees in the fourth quarter; deposits on the balance sheet down nearly 20% from the end of 2024; revenue from deposit and referral fees down 66%; about $412 million (38%) of deposits uninsured; and a leverage ratio of 11.91% and a common equity tier 1 ratio of 17.73%, well capitalised by traditional measures.","source_ids":["src-035"],"entity_ids":["evolve"],"qualification":"Newsletter reading of regulatory filings; the FDIC data in the record confirm the year-end deposit, uninsured-deposit and net-loss figures.","response":"","outcome":""},"reading":"Attributed: A fintech industry newsletter, reading the bank's call report for the fourth quarter of 2025, reported a year-to-date net loss of $14 million at the end of September 2025 narrowing to $3 million for the year, helped by lower (technically negative) legal, consulting and advisory fees in the fourth quarter; deposits on the balance sheet down nearly 20% from the end of 2024; revenue from deposit and referral fees down 66%; about $412 million (38%) of deposits uninsured; and a leverage ratio of 11.91% and a common equity tier 1 ratio of 17.73%, well capitalised by traditional measures."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-obd-reserve","record":{"id":"c-fin-obd-reserve","kind":"attributed","text":"The same report noted a new liability of $26,153,000 in the bank's fourth-quarter 2025 call report described as an 'Open Banking Division Reserve'; the newsletter said its purpose was unclear and listed possibilities such as further payments to end users and contingent liabilities from the Synapse matter and civil cases.","source_ids":["src-035"],"entity_ids":["evolve"],"qualification":"The purpose of the reserve is not disclosed in the retained record; the possibilities listed are the newsletter's speculation.","response":"A representative for the bank did not respond to the newsletter's questions or request for comment.","outcome":""},"reading":"Attributed: The same report noted a new liability of $26,153,000 in the bank's fourth-quarter 2025 call report described as an 'Open Banking Division Reserve'; the newsletter said its purpose was unclear and listed possibilities such as further payments to end users and contingent liabilities from the Synapse matter and civil cases."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-bancorp-distress","record":{"id":"c-fin-bancorp-distress","kind":"attributed","text":"A fintech industry newsletter reported in February 2026 that Evolve Bancorp's parent-only FR Y-9SP report for 2025 showed no operating income, a net loss of about $7.4 million, $51.1 million of long-term borrowings and $5,791,000 of interest payable on subordinated debt, and that the holding company had missed coupon payments on at least some notes; the newsletter called it functionally insolvent.","source_ids":["src-035","src-003"],"entity_ids":["evolve-bancorp"],"qualification":"The retained copy of the 2025 FR Y-9SP is a blank form, so these figures could not be checked against it; 'functionally insolvent' is the newsletter's characterisation. Under the June 2024 order, interest payments on the holding company's subordinated debentures require prior regulatory approval.","response":"","outcome":"The same report said Stifel was offering two tranches of the holding company's notes at 40 cents on the dollar, citing the missed coupon payments.","adverse_subject_ids":["evolve-bancorp"]},"reading":"Attributed: A fintech industry newsletter reported in February 2026 that Evolve Bancorp's parent-only FR Y-9SP report for 2025 showed no operating income, a net loss of about $7.4 million, $51.1 million of long-term borrowings and $5,791,000 of interest payable on subordinated debt, and that the holding company had missed coupon payments on at least some notes; the newsletter called it functionally insolvent."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-bancorp-notes","record":{"id":"c-fin-bancorp-notes","kind":"attributed","text":"According to correspondence reviewed by a fintech industry newsletter, Stifel was soliciting bids in early 2026 for two $5 million tranches of Evolve Bancorp notes, one paying 4% and maturing in April 2031 and the other 4.5% maturing in April 2032, at an asking price of 40 cents on the dollar, noting that the debt was unrated and that 'the company has missed its most recent coupon payments, indicating credit distress'. The newsletter quoted Stifel's view that a CFPB redress allocation could reduce any net liability of Evolve from the Synapse bankruptcy, stressing that this was speculative.","source_ids":["src-035","src-102"],"entity_ids":["evolve-bancorp","stifel","john-pitts"],"qualification":"Third-party offering material as reported; Stifel's estimates are not in the retained record. Director John T. Pitts Jr. is registered with Stifel in Memphis; the record does not show any role for him in the offering.","response":"","outcome":""},"reading":"Attributed: According to correspondence reviewed by a fintech industry newsletter, Stifel was soliciting bids in early 2026 for two $5 million tranches of Evolve Bancorp notes, one paying 4% and maturing in April 2031 and the other 4.5% maturing in April 2032, at an asking price of 40 cents on the dollar, noting that the debt was unrated and that 'the company has missed its most recent coupon payments, indicating credit distress'. The newsletter quoted Stifel's view that a CFPB redress allocation could reduce any net liability of Evolve from the Synapse bankruptcy, stressing that this was speculative."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-auditors","record":{"id":"c-fin-auditors","kind":"attributed","text":"A fintech industry newsletter reported, from the bank's annual audit reports for 2021 to 2024 obtained from the Federal Reserve under the Freedom of Information Act, that Crowe was Evolve's external auditor for 2021, 2022 and 2023 and KPMG for 2024, and that each year's audit opinion was unqualified, with the auditors also attesting to internal control over financial reporting, although Evolve had been dealing with ledger discrepancies with Synapse of hundreds of millions of dollars since at least November 2022.","source_ids":["src-047"],"entity_ids":["evolve","crowe","kpmg","synapse"],"qualification":"Reported by the newsletter; the audit reports are not in the retained record.","response":"","outcome":""},"reading":"Attributed: A fintech industry newsletter reported, from the bank's annual audit reports for 2021 to 2024 obtained from the Federal Reserve under the Freedom of Information Act, that Crowe was Evolve's external auditor for 2021, 2022 and 2023 and KPMG for 2024, and that each year's audit opinion was unqualified, with the auditors also attesting to internal control over financial reporting, although Evolve had been dealing with ledger discrepancies with Synapse of hundreds of millions of dollars since at least November 2022."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-fin-crowe-confirmation","record":{"id":"c-fin-crowe-confirmation","kind":"attributed","text":"The same report said that in February 2024, during its 2023 audit, Crowe asked Synapse to confirm its cash balances at Evolve as of December 31, 2023; according to e-mails filed in the bankruptcy case, Synapse's general counsel noted that Evolve's account list included 113 accounts that were not on the daily data feed and omitted 29 that should have been there, and sought to discuss this with Scot Lenoir and the bank's outside counsel, but Evolve did not respond. Crowe issued an unqualified opinion for 2023.","source_ids":["src-047"],"entity_ids":["evolve","crowe","synapse","scot-lenoir"],"qualification":"Newsletter account of e-mails filed as exhibits; the exhibits are not in the retained record.","response":"","outcome":""},"reading":"Attributed: The same report said that in February 2024, during its 2023 audit, Crowe asked Synapse to confirm its cash balances at Evolve as of December 31, 2023; according to e-mails filed in the bankruptcy case, Synapse's general counsel noted that Evolve's account list included 113 accounts that were not on the daily data feed and omitted 29 that should have been there, and sought to discuss this with Scot Lenoir and the bank's outside counsel, but Evolve did not respond. Crowe issued an unqualified opinion for 2023."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ceo-arrest","record":{"id":"c-ceo-arrest","kind":"attributed","text":"On October 23, 2025 FBI agents arrested Robert 'Bob' Hartheimer, Evolve's chief executive since August 2025, at the bank's headquarters on Poplar Avenue in Memphis under a federal court-authorised warrant. A local television station reported that he faced charges of sexual exploitation of a minor and distribution of obscene material.","source_ids":["src-006","src-004","src-072","src-014"],"entity_ids":["robert-hartheimer","evolve"],"qualification":"The description of the charges at the time of arrest comes from a local broadcaster citing the FBI; the criminal complaint was filed under seal on October 24, 2025 and is not in the retained record.","response":"The bank said the matter was personal and unrelated to the bank or its operations, that it was in close contact with the U.S. Attorney's office and had offered its full cooperation.","outcome":"On January 5, 2026 he pleaded guilty to both counts of a federal criminal information, and on June 4, 2026 he was sentenced to 51 months in prison; the United States filed a notice of appeal on July 2, 2026.","adverse_subject_ids":["robert-hartheimer"]},"reading":"Attributed: On October 23, 2025 FBI agents arrested Robert 'Bob' Hartheimer, Evolve's chief executive since August 2025, at the bank's headquarters on Poplar Avenue in Memphis under a federal court-authorised warrant. A local television station reported that he faced charges of sexual exploitation of a minor and distribution of obscene material."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ceo-dismissal","record":{"id":"c-ceo-dismissal","kind":"fact","text":"The bank's board said it was treating the matter 'with the utmost seriousness' and that Hartheimer had been terminated effective immediately; an online encyclopedia dates the firing to the day after the arrest.","source_ids":["src-004","src-014"],"entity_ids":["robert-hartheimer","evolve"],"qualification":"","response":"","outcome":""},"reading":"Fact: The bank's board said it was treating the matter 'with the utmost seriousness' and that Hartheimer had been terminated effective immediately; an online encyclopedia dates the firing to the day after the arrest."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ceo-plea","record":{"id":"c-ceo-plea","kind":"fact","text":"In United States v. Hartheimer (W.D. Tenn. No. 2:25-cr-20314), a two-count criminal information was filed on December 15, 2025. On January 5, 2026 Robert Herman Hartheimer waived indictment and pleaded guilty to both counts before Chief Judge Sheryl H. Lipman under a written plea agreement; the court accepted the plea and he was remanded into custody.","source_ids":["src-072"],"entity_ids":["robert-hartheimer"],"qualification":"","response":"","outcome":"","adverse_subject_ids":["robert-hartheimer"]},"reading":"Fact: In United States v. Hartheimer (W.D. Tenn. No. 2:25-cr-20314), a two-count criminal information was filed on December 15, 2025. On January 5, 2026 Robert Herman Hartheimer waived indictment and pleaded guilty to both counts before Chief Judge Sheryl H. Lipman under a written plea agreement; the court accepted the plea and he was remanded into custody."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"c-ceo-sentence","record":{"id":"c-ceo-sentence","kind":"fact","text":"On June 4, 2026 the court sentenced Hartheimer to 51 months in prison followed by five years of supervised release with specialised sex-offender conditions, and ordered a $200 special assessment, a $10,000 assessment under the Justice for Victims of Trafficking Act and a $10,000 assessment under the Amy, Vicky, and Andy Child Pornography Victim Assistance Act. On July 2, 2026 the United States filed a notice of appeal.","source_ids":["src-072"],"entity_ids":["robert-hartheimer"],"qualification":"The retained docket does not describe the specific statutes of conviction or the grounds of the government's appeal.","response":"","outcome":"","adverse_subject_ids":["robert-hartheimer"]},"reading":"Fact: On June 4, 2026 the court sentenced Hartheimer to 51 months in prison followed by five years of supervised release with specialised sex-offender conditions, and ordered a $200 special assessment, a $10,000 assessment under the Justice for Victims of Trafficking Act and a $10,000 assessment under the Amy, Vicky, and Andy Child Pornography Victim Assistance Act. On July 2, 2026 the United States filed a notice of appeal."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-3dbb00fb237ef3fdf297efc9","record":{"id":"display-claim-3dbb00fb237ef3fdf297efc9","kind":"analysis","text":"This edition brings together the regulator, court, company and press records retained on Evolve Bank & Trust: the holding-company chain and officers from 2006 to 2025, each documented fintech partnership and how customers' money was held, the Synapse dispute as described by the CFPB, FINRA, the bankruptcy trustee, the other partner banks and Evolve itself, the terms of the 2024 order, the earlier enforcement cases, the 2024 data breach and the bank's results. Each allegation is kept beside the response and outcome found in the record, and the regulators', senators' and newsletter's assessments remain attributed to them.","source_ids":["src-001","src-005","src-024","src-003","src-007","src-101","src-009","src-010","src-033","src-025","src-002","src-017","src-018","src-039","src-108","src-004","src-008","src-054","src-014","src-006","src-072","src-097","src-114","src-012","src-031","src-035","src-050","src-096","src-029","src-052","src-027","src-030","src-037","src-079","src-080","src-104","src-113","src-044","src-082","src-081","src-083","src-084","src-077","src-115","src-117","src-118","src-028","src-119"],"entity_ids":["evolve","evolve-bancorp","corporation-service-company","evolve-financial-group","scot-lenoir","evolve-advisors","evolve-benefits-group","evolve-financial-services","evolve-mortgage-services","evolve-securities","scott-stafford","al-bright","donald-clanton","lewis-holland","lon-magness","john-pitts","steve-valentine","monica-wharton","mark-mosteller","robin-bedsole","hank-word","joelle-weltzin","robert-hartheimer","klaros","jasper","promontory","fdic","arlon-duke","alex-johnston","branch","marqeta","mercury","stripe","dave","step","b9","mbanq","synapse","sankaet-pathak","synapse-brokerage","cfpb","finra","amg-national-trust","lineage-bank","american-bank","dfpi","yotta","federal-reserve-board","arkansas-state-bank-department","federal-reserve-bank-st-louis","affirm","capitalj","coastal-community-bank"],"premise_claim_ids":["c-id-fdic-record","c-id-fed-member","c-id-name-history","c-id-state-charter","c-id-memphis-offices","c-id-mississippi","c-id-lei","c-id-screening","c-grp-2005-purchase","c-grp-2006-structure","c-grp-fdic-holding","c-grp-owners-unknown","c-brd-2023-2024","c-brd-2025","c-brd-hartheimer-appointed","c-ppl-hartheimer-career","c-ceo-dismissal","c-ceo-arrest","c-brd-after-hartheimer","c-brd-no-new-ceo","c-baas-origin","c-reg-order-baas","c-fin-growth-2019-2022","c-baas-departures","c-syn-company","c-syn-agreements","c-syn-deficit-known","c-syn-freeze","c-rec-trustee-fbo","c-rec-shortfall","c-rec-cfpb-fund","c-reg-order","c-reg-order-findings","c-reg-order-in-force","c-lit-colorado","c-brc-attack","c-brc-maine","c-brc-mdl","c-brc-settlement","c-fin-fdic-series","c-fin-2026-h1","c-fin-bancorp-distress","c-baas-coastal"],"qualification":"","response":"","outcome":""},"reading":"Analysis: This edition brings together the regulator, court, company and press records retained on Evolve Bank & Trust: the holding-company chain and officers from 2006 to 2025, each documented fintech partnership and how customers' money was held, the Synapse dispute as described by the CFPB, FINRA, the bankruptcy trustee, the other partner banks and Evolve itself, the terms of the 2024 order, the earlier enforcement cases, the 2024 data breach and the bank's results. Each allegation is kept beside the response and outcome found in the record, and the regulators', senators' and newsletter's assessments remain attributed to them."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-c77d69db5f2bcf22e4efd4e5","record":{"id":"display-claim-c77d69db5f2bcf22e4efd4e5","kind":"analysis","text":"In the FDIC's institution record, Evolve Bank & Trust is an active, insured, Arkansas-chartered commercial bank in West Memphis with FDIC Certificate No. 1299 and Federal Reserve RSSD ID 592448, established on June 5, 1925 and insured since 1934. It is a state member bank of the Federal Reserve System supervised from the St. Louis district, with ten domestic offices. The bank opened as First State Bank in Cross County, Arkansas, and took its present name and trust powers in 2005; the Arkansas regulator lists it under state charter 568 with Evolve Bancorp, Inc. as its bank holding company.","source_ids":["src-001","src-005","src-024"],"entity_ids":["evolve","evolve-bancorp"],"premise_claim_ids":["c-id-fdic-record","c-id-fed-member","c-id-name-history","c-id-state-charter"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In the FDIC's institution record, Evolve Bank & Trust is an active, insured, Arkansas-chartered commercial bank in West Memphis with FDIC Certificate No. 1299 and Federal Reserve RSSD ID 592448, established on June 5, 1925 and insured since 1934. It is a state member bank of the Federal Reserve System supervised from the St. Louis district, with ten domestic offices. The bank opened as First State Bank in Cross County, Arkansas, and took its present name and trust powers in 2005; the Arkansas regulator lists it under state charter 568 with Evolve Bancorp, Inc. as its bank holding company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-2be53d520dd7a690c5181664","record":{"id":"display-claim-2be53d520dd7a690c5181664","kind":"analysis","text":"Although its charter and head office are in West Memphis, its executives work from Poplar Avenue in Memphis, Tennessee, where the Federal Reserve addressed its 2024 order. The bank is also registered in Mississippi as an Arkansas corporation. A screening record compiled from GLEIF data gives it the legal entity identifier 549300IRXW9RSZM2B951, though the LEI field of the FDIC record is blank and no GLEIF record was retained; the same screening data tag the bank and its holding company with regulatory-action topics from the Federal Reserve's 2022 and 2024 releases, without any sanctions topic; these are third-party tags derived from published releases, not a fresh sanctions screening.","source_ids":["src-003","src-007","src-101","src-009","src-001","src-010"],"entity_ids":["evolve","corporation-service-company","evolve-bancorp"],"premise_claim_ids":["c-id-memphis-offices","c-id-mississippi","c-id-lei","c-id-screening"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Although its charter and head office are in West Memphis, its executives work from Poplar Avenue in Memphis, Tennessee, where the Federal Reserve addressed its 2024 order. The bank is also registered in Mississippi as an Arkansas corporation. A screening record compiled from GLEIF data gives it the legal entity identifier 549300IRXW9RSZM2B951, though the LEI field of the FDIC record is blank and no GLEIF record was retained; the same screening data tag the bank and its holding company with regulatory-action topics from the Federal Reserve's 2022 and 2024 releases, without any sanctions topic; these are third-party tags derived from published releases, not a fresh sanctions screening."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-6dcd06863ce4153af1e878fd","record":{"id":"display-claim-6dcd06863ce4153af1e878fd","kind":"analysis","text":"In 2005 Evolve Financial Group, organised by B. Scot Lenoir, sought to buy Parkin Bancorp, the holding company of First State Bank; by mid-2006 Evolve Financial Group was Parkin Bancorp's holding company. The FDIC now names Evolve Bancorp, Inc. (RSSD 1142411), the former Parkin Bancorp, as the bank's holding company. Who owns the holding company is not shown in the retained record: requests for its FR Y-6 reports for 2024 and 2025 returned an error page, which shows only that they could not be retrieved, not that they were not filed. The regulator's reports for 2023 and 2024 list Lenoir as the bank's chairman and Scott Stafford as chief executive; by mid-2025 neither was among the six directors listed, and by August 2025 Stephen Valentine was chairman of the board.","source_ids":["src-033","src-025","src-001","src-002","src-017","src-018","src-039","src-108","src-024","src-004","src-008"],"entity_ids":["evolve-financial-group","evolve-bancorp","scot-lenoir","evolve","evolve-advisors","evolve-benefits-group","evolve-financial-services","evolve-mortgage-services","evolve-securities","scott-stafford","al-bright","donald-clanton","lewis-holland","lon-magness","john-pitts","steve-valentine","monica-wharton","mark-mosteller","robin-bedsole","hank-word","joelle-weltzin","robert-hartheimer"],"premise_claim_ids":["c-grp-2005-purchase","c-grp-2006-structure","c-grp-fdic-holding","c-grp-owners-unknown","c-brd-2023-2024","c-brd-2025","c-brd-hartheimer-appointed"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In 2005 Evolve Financial Group, organised by B. Scot Lenoir, sought to buy Parkin Bancorp, the holding company of First State Bank; by mid-2006 Evolve Financial Group was Parkin Bancorp's holding company. The FDIC now names Evolve Bancorp, Inc. (RSSD 1142411), the former Parkin Bancorp, as the bank's holding company. Who owns the holding company is not shown in the retained record: requests for its FR Y-6 reports for 2024 and 2025 returned an error page, which shows only that they could not be retrieved, not that they were not filed. The regulator's reports for 2023 and 2024 list Lenoir as the bank's chairman and Scott Stafford as chief executive; by mid-2025 neither was among the six directors listed, and by August 2025 Stephen Valentine was chairman of the board."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-2a73dadf2b5c3ddee9184db5","record":{"id":"display-claim-2a73dadf2b5c3ddee9184db5","kind":"analysis","text":"On August 13, 2025 the board appointed Robert 'Bob' Hartheimer, a former FDIC official, as chief executive. He was arrested at the bank's Memphis headquarters on October 23, 2025 and the board terminated him with immediate effect; the bank said the matter was personal and unrelated to the bank or its operations, that it was in close contact with the U.S. Attorney's office and had offered its full cooperation. He pleaded guilty to two federal counts on January 5, 2026, was sentenced on June 4, 2026 to 51 months in prison, and the United States appealed on July 2, 2026. President and chief financial officer Mark Mosteller and general counsel Joelle Weltzin resumed running the bank; the retained copy of the bank's news page announces no new chief executive, which does not exclude an announcement elsewhere.","source_ids":["src-008","src-054","src-004","src-014","src-006","src-072","src-097","src-114"],"entity_ids":["robert-hartheimer","klaros","jasper","promontory","fdic","evolve","mark-mosteller","joelle-weltzin","arlon-duke","alex-johnston"],"premise_claim_ids":["c-ppl-hartheimer-career","c-ceo-dismissal","c-ceo-arrest","c-brd-after-hartheimer","c-brd-no-new-ceo"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On August 13, 2025 the board appointed Robert 'Bob' Hartheimer, a former FDIC official, as chief executive. He was arrested at the bank's Memphis headquarters on October 23, 2025 and the board terminated him with immediate effect; the bank said the matter was personal and unrelated to the bank or its operations, that it was in close contact with the U.S. Attorney's office and had offered its full cooperation. He pleaded guilty to two federal counts on January 5, 2026, was sentenced on June 4, 2026 to 51 months in prison, and the United States appealed on July 2, 2026. President and chief financial officer Mark Mosteller and general counsel Joelle Weltzin resumed running the bank; the retained copy of the bank's news page announces no new chief executive, which does not exclude an announcement elsewhere."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-27a00a6305c7f38e6d7495ee","record":{"id":"display-claim-27a00a6305c7f38e6d7495ee","kind":"analysis","text":"Evolve started its Open Banking business in 2017, letting fintech partners build its deposit accounts and payments into their own apps; an online encyclopedia names Branch, Marqeta, Mercury and Stripe among the fintechs it served. The Federal Reserve's order describes the strategy as offering deposit accounts and payment processing to fintech partners, which in turn serve end users. Senators noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later. Reading the bank's call report and partner announcements, a fintech industry newsletter reported in February 2026 that major programmes, including Mercury and Dave, had left the bank; Mercury had announced its move to other banks in March 2025. A bank spokesperson said in March 2025 that Evolve remained focused on strengthening its existing relationships and exploring new opportunities with established fintechs.","source_ids":["src-012","src-004","src-003","src-031","src-035","src-050","src-096"],"entity_ids":["evolve","branch","marqeta","mercury","stripe","dave","step","b9","mbanq"],"premise_claim_ids":["c-baas-origin","c-reg-order-baas","c-fin-growth-2019-2022","c-baas-departures"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve started its Open Banking business in 2017, letting fintech partners build its deposit accounts and payments into their own apps; an online encyclopedia names Branch, Marqeta, Mercury and Stripe among the fintechs it served. The Federal Reserve's order describes the strategy as offering deposit accounts and payment processing to fintech partners, which in turn serve end users. Senators noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later. Reading the bank's call report and partner announcements, a fintech industry newsletter reported in February 2026 that major programmes, including Mercury and Dave, had left the bank; Mercury had announced its move to other banks in March 2025. A bank spokesperson said in March 2025 that Evolve remained focused on strengthening its existing relationships and exploring new opportunities with established fintechs."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-d39c05917c7e53a0b51afa73","record":{"id":"display-claim-d39c05917c7e53a0b51afa73","kind":"analysis","text":"Synapse Financial Technologies, which provided technology and other services to fintech platforms and partner banks, signed a Bank Services Agreement with Evolve in 2017. According to the CFPB, by September 2023 both companies knew of a deficit of tens of millions of dollars in the funds Evolve held for end users and blamed each other; Evolve is not a party to that complaint, and the deficit's cause remains disputed. The CFPB says the dispute was still unresolved when it sued Synapse in August 2025. Synapse filed for Chapter 11 on April 22, 2024; on May 11, according to the CFPB, Synapse cut off the bank's access to its dashboard and ledger reports and Evolve froze all activity for every end user. The bank began releasing funds in November 2024, and FINRA alleges that customers whose funds were allocated to it recovered only a fraction. These are allegations in the CFPB and FINRA complaints; an online encyclopedia describes the freeze as lasting five months and locking tens of thousands of customers out of their accounts.","source_ids":["src-029","src-052","src-027","src-004"],"entity_ids":["synapse","sankaet-pathak","synapse-brokerage","evolve","cfpb","finra"],"premise_claim_ids":["c-syn-company","c-syn-agreements","c-syn-deficit-known","c-syn-freeze"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Synapse Financial Technologies, which provided technology and other services to fintech platforms and partner banks, signed a Bank Services Agreement with Evolve in 2017. According to the CFPB, by September 2023 both companies knew of a deficit of tens of millions of dollars in the funds Evolve held for end users and blamed each other; Evolve is not a party to that complaint, and the deficit's cause remains disputed. The CFPB says the dispute was still unresolved when it sued Synapse in August 2025. Synapse filed for Chapter 11 on April 22, 2024; on May 11, according to the CFPB, Synapse cut off the bank's access to its dashboard and ledger reports and Evolve froze all activity for every end user. The bank began releasing funds in November 2024, and FINRA alleges that customers whose funds were allocated to it recovered only a fraction. These are allegations in the CFPB and FINRA complaints; an online encyclopedia describes the freeze as lasting five months and locking tens of thousands of customers out of their accounts."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-8665945cd5f395f5ee401483","record":{"id":"display-claim-8665945cd5f395f5ee401483","kind":"analysis","text":"The bankruptcy trustee reported that on May 24, 2024 Evolve held $46.9 million of Synapse end users' funds in for-benefit-of accounts, 44% of which it had paid out by November 12, 2024, against 99% at AMG National Trust. Her estimate of the overall shortfall across Synapse's partner banks was $65 million to $95 million, which neither she nor the CFPB attributed to a particular bank. In November 2025 the CFPB allocated $46,248,291 from its Civil Penalty Fund to eligible victims of the Synapse bankruptcy.","source_ids":["src-030","src-029","src-037","src-035"],"entity_ids":["evolve","amg-national-trust","lineage-bank","american-bank","synapse","cfpb","dfpi","yotta"],"premise_claim_ids":["c-rec-trustee-fbo","c-rec-shortfall","c-rec-cfpb-fund"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The bankruptcy trustee reported that on May 24, 2024 Evolve held $46.9 million of Synapse end users' funds in for-benefit-of accounts, 44% of which it had paid out by November 12, 2024, against 99% at AMG National Trust. Her estimate of the overall shortfall across Synapse's partner banks was $65 million to $95 million, which neither she nor the CFPB attributed to a particular bank. In November 2025 the CFPB allocated $46,248,291 from its Civil Penalty Fund to eligible victims of the Synapse bankruptcy."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-09d298065b9104a714d81986","record":{"id":"display-claim-09d298065b9104a714d81986","kind":"analysis","text":"Effective June 11, 2024, the Federal Reserve Board and the Arkansas State Bank Department issued a cease-and-desist order, upon consent, to the bank and Evolve Bancorp after examinations found risk-management, consumer-compliance and anti-money-laundering deficiencies in the Open Banking Division; the companies consented to settle without a formal proceeding, before any notice of charges, hearing or adjudication, so the order is not a court judgment, and the order records that they had begun remedial action. The Board's release lists through October 16, 2026 show no termination of the order, although such a gap is not an official statement of its status. Synapse end users have sued Evolve, its holding company and three other partner banks in a consolidated class action in Colorado, alleging that the banks failed to safeguard customer funds; there is no ruling on the merits.","source_ids":["src-003","src-079","src-080","src-104","src-113"],"entity_ids":["evolve","evolve-bancorp","federal-reserve-board","arkansas-state-bank-department","federal-reserve-bank-st-louis","amg-national-trust","lineage-bank","american-bank"],"premise_claim_ids":["c-reg-order","c-reg-order-findings","c-reg-order-in-force","c-lit-colorado"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Effective June 11, 2024, the Federal Reserve Board and the Arkansas State Bank Department issued a cease-and-desist order, upon consent, to the bank and Evolve Bancorp after examinations found risk-management, consumer-compliance and anti-money-laundering deficiencies in the Open Banking Division; the companies consented to settle without a formal proceeding, before any notice of charges, hearing or adjudication, so the order is not a court judgment, and the order records that they had begun remedial action. The Board's release lists through October 16, 2026 show no termination of the order, although such a gap is not an official statement of its status. Synapse end users have sued Evolve, its holding company and three other partner banks in a consolidated class action in Colorado, alleging that the banks failed to safeguard customer funds; there is no ruling on the merits."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-908a071bb601c7b4c158fe28","record":{"id":"display-claim-908a071bb601c7b4c158fe28","kind":"analysis","text":"Separately, a ransomware attack by the LockBit group, first noticed in late May 2024, exposed data that the bank's notice to Maine's attorney general, retained as an archived web copy of the state's listing, put at 7,640,112 people. The resulting suits were consolidated in 2024 as MDL No. 3127 in the Western District of Tennessee, where the court made no finding of liability on the plaintiffs' allegations, and settled after a mediation in January 2025; Evolve denies any wrongdoing.","source_ids":["src-044","src-082","src-081","src-083","src-084","src-077","src-115"],"entity_ids":["evolve","affirm","branch","capitalj","yotta"],"premise_claim_ids":["c-brc-attack","c-brc-maine","c-brc-mdl","c-brc-settlement"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Separately, a ransomware attack by the LockBit group, first noticed in late May 2024, exposed data that the bank's notice to Maine's attorney general, retained as an archived web copy of the state's listing, put at 7,640,112 people. The resulting suits were consolidated in 2024 as MDL No. 3127 in the Western District of Tennessee, where the court made no finding of liability on the plaintiffs' allegations, and settled after a mediation in January 2025; Evolve denies any wrongdoing."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-b94ac878426a2f24db5d6ec6","record":{"id":"display-claim-b94ac878426a2f24db5d6ec6","kind":"analysis","text":"Bank-only FDIC data, which exclude the holding company, show the bank's total assets at about $1.29 billion and deposits at about $1.07 billion at the end of 2025, after a net loss of $3.0 million for the year, and a further year-to-date loss of $865,000 at June 30, 2026. The holding company, according to a fintech industry newsletter, had no operating income in 2025 and had missed coupon payments on some of its notes, which a broker was offering at 40 cents on the dollar. In April 2026 Coastal Community Bank agreed a non-binding term sheet to buy assets and deposits of some Evolve BaaS programmes, but in July it said it was no longer pursuing the deal.","source_ids":["src-117","src-118","src-001","src-035","src-003","src-028","src-119"],"entity_ids":["evolve","fdic","evolve-bancorp","coastal-community-bank"],"premise_claim_ids":["c-fin-fdic-series","c-fin-2026-h1","c-fin-bancorp-distress","c-baas-coastal"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Bank-only FDIC data, which exclude the holding company, show the bank's total assets at about $1.29 billion and deposits at about $1.07 billion at the end of 2025, after a net loss of $3.0 million for the year, and a further year-to-date loss of $865,000 at June 30, 2026. The holding company, according to a fintech industry newsletter, had no operating income in 2025 and had missed coupon payments on some of its notes, which a broker was offering at 40 cents on the dollar. In April 2026 Coastal Community Bank agreed a non-binding term sheet to buy assets and deposits of some Evolve BaaS programmes, but in July it said it was no longer pursuing the deal."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-feacb626c78c65ce1ecb58dc","record":{"id":"display-claim-feacb626c78c65ce1ecb58dc","kind":"analysis","text":"In June 2005 a regional business publication reported that Evolve Financial Group of Memphis, a financial-services venture formed in January 2004 and organised by B. Scot Lenoir, was seeking to buy Parkin Bancorp Inc., the holding company of First State Bank of Parkin, which reported total assets of nearly $22 million at March 31, 2005. The Federal Reserve's list records Evolve Financial Group (RSSD 3343351) as a bank holding company from August 1, 2005 to December 30, 2013, and RSSD 1142411 as a bank holding company since February 10, 1987, named Parkin Bancorp, Inc. until the end of 2006 and Evolve Bancorp, Inc. afterwards.","source_ids":["src-033","src-013"],"entity_ids":["evolve-financial-group","evolve-bancorp","scot-lenoir","evolve"],"premise_claim_ids":["c-grp-2005-purchase","c-grp-fed-list"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In June 2005 a regional business publication reported that Evolve Financial Group of Memphis, a financial-services venture formed in January 2004 and organised by B. Scot Lenoir, was seeking to buy Parkin Bancorp Inc., the holding company of First State Bank of Parkin, which reported total assets of nearly $22 million at March 31, 2005. The Federal Reserve's list records Evolve Financial Group (RSSD 3343351) as a bank holding company from August 1, 2005 to December 30, 2013, and RSSD 1142411 as a bank holding company since February 10, 1987, named Parkin Bancorp, Inc. until the end of 2006 and Evolve Bancorp, Inc. afterwards."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-8dd1b8324c65d08eca2409d0","record":{"id":"display-claim-8dd1b8324c65d08eca2409d0","kind":"analysis","text":"The Arkansas report with data as of June 30, 2006 shows the two tiers. Evolve Financial Group, with Lenoir as chairman and chief executive and Scott Stafford as secretary, listed as subsidiaries Parkin Bancorp, the bank and five service companies: Evolve Advisors, Evolve Benefits Group, Evolve Financial Services, Evolve Mortgage Services and Evolve Securities. Parkin Bancorp, with the same chairman and secretary, named Evolve Financial Group as its holding company and the bank, then based in Parkin, as its subsidiary.","source_ids":["src-025"],"entity_ids":["evolve-financial-group","evolve-bancorp","evolve","evolve-advisors","evolve-benefits-group","evolve-financial-services","evolve-mortgage-services","evolve-securities","scot-lenoir","scott-stafford"],"premise_claim_ids":["c-grp-2006-structure"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Arkansas report with data as of June 30, 2006 shows the two tiers. Evolve Financial Group, with Lenoir as chairman and chief executive and Scott Stafford as secretary, listed as subsidiaries Parkin Bancorp, the bank and five service companies: Evolve Advisors, Evolve Benefits Group, Evolve Financial Services, Evolve Mortgage Services and Evolve Securities. Parkin Bancorp, with the same chairman and secretary, named Evolve Financial Group as its holding company and the bank, then based in Parkin, as its subsidiary."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ac356bdb9ba089a75a49ef49","record":{"id":"display-claim-ac356bdb9ba089a75a49ef49","kind":"analysis","text":"By June 30, 2015 Evolve Bancorp of West Memphis held the bank as its only listed subsidiary, with Lenoir as chairman and Stafford as secretary. The 2024 report lists Lenoir as chairman, Stafford as secretary and Robin Bedsole as controller, with two subsidiaries: the bank and Evolve Commercial Finance of Memphis. In the 2025 report Stephen Valentine is chairman, Alvinor Bright, Jr. vice chairman and Mark Mosteller chief financial officer. The FDIC record names Evolve Bancorp (RSSD 1142411) as the bank's holding company.","source_ids":["src-070","src-039","src-024","src-001"],"entity_ids":["evolve-bancorp","evolve","scot-lenoir","scott-stafford","evolve-commercial-finance","robin-bedsole","steve-valentine","al-bright","mark-mosteller"],"premise_claim_ids":["c-grp-2015","c-grp-2024","c-grp-2025","c-grp-fdic-holding"],"qualification":"","response":"","outcome":""},"reading":"Analysis: By June 30, 2015 Evolve Bancorp of West Memphis held the bank as its only listed subsidiary, with Lenoir as chairman and Stafford as secretary. The 2024 report lists Lenoir as chairman, Stafford as secretary and Robin Bedsole as controller, with two subsidiaries: the bank and Evolve Commercial Finance of Memphis. In the 2025 report Stephen Valentine is chairman, Alvinor Bright, Jr. vice chairman and Mark Mosteller chief financial officer. The FDIC record names Evolve Bancorp (RSSD 1142411) as the bank's holding company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-07819a3ee36fba28c23d4715","record":{"id":"display-claim-07819a3ee36fba28c23d4715","kind":"analysis","text":"Evolve Commercial Finance, Inc. filed a 2023 annual report in Florida as a foreign profit corporation, giving 6000 Poplar Avenue in Memphis as its principal address and listing Stafford as president, Lenoir as director, Mosteller as treasurer and Henry A. Barham III as secretary, with Corporation Service Company as registered agent.","source_ids":["src-116"],"entity_ids":["evolve-commercial-finance","scott-stafford","scot-lenoir","mark-mosteller","henry-barham","corporation-service-company"],"premise_claim_ids":["c-grp-ecf-florida"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve Commercial Finance, Inc. filed a 2023 annual report in Florida as a foreign profit corporation, giving 6000 Poplar Avenue in Memphis as its principal address and listing Stafford as president, Lenoir as director, Mosteller as treasurer and Henry A. Barham III as secretary, with Corporation Service Company as registered agent."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-1f88bf085928fce728a26749","record":{"id":"display-claim-1f88bf085928fce728a26749","kind":"analysis","text":"Evolve Bancorp's unaudited balance sheet at March 31, 2022 reported total assets of $777.7 million, $40 million of Federal Home Loan Bank advances, $31.1 million of subordinated debt, $3.4 million of Class A preferred stock, 4,646,210 common shares outstanding and shareholders' equity of $65.3 million. Its first-quarter letter, signed by Lenoir as chairman, reported $10.5 million of subordinated notes issued in March 2022. At March 31, 2014 the company had $4.7 million of Small Business Lending Fund money from the Treasury outstanding at a 1.00% dividend rate.","source_ids":["src-034","src-040"],"entity_ids":["evolve-bancorp","evolve","scot-lenoir","us-treasury"],"premise_claim_ids":["c-grp-shares-2022","c-fin-q1-2022","c-grp-sblf"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve Bancorp's unaudited balance sheet at March 31, 2022 reported total assets of $777.7 million, $40 million of Federal Home Loan Bank advances, $31.1 million of subordinated debt, $3.4 million of Class A preferred stock, 4,646,210 common shares outstanding and shareholders' equity of $65.3 million. Its first-quarter letter, signed by Lenoir as chairman, reported $10.5 million of subordinated notes issued in March 2022. At March 31, 2014 the company had $4.7 million of Small Business Lending Fund money from the Treasury outstanding at a 1.00% dividend rate."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-b43f97cfc710285773128427","record":{"id":"display-claim-b43f97cfc710285773128427","kind":"analysis","text":"The retained record does not identify Evolve Bancorp's principal shareholders. Requests for its FR Y-6 reports for 2024 and 2025 returned an error page, which shows only that the filings could not be retrieved at that time, not that they were not filed, and the retained 2025 FR Y-9SP is a blank form. Director Donald B. Clanton has reported being a minor stockholder of the bank since 2005.","source_ids":["src-002","src-017","src-018","src-023"],"entity_ids":["evolve-bancorp","donald-clanton","evolve"],"premise_claim_ids":["c-grp-owners-unknown","c-grp-minor-holder"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The retained record does not identify Evolve Bancorp's principal shareholders. Requests for its FR Y-6 reports for 2024 and 2025 returned an error page, which shows only that the filings could not be retrieved at that time, not that they were not filed, and the retained 2025 FR Y-9SP is a blank form. Director Donald B. Clanton has reported being a minor stockholder of the bank since 2005."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-645dfede6f7d3d89491686a5","record":{"id":"display-claim-645dfede6f7d3d89491686a5","kind":"analysis","text":"Under the June 2024 cease-and-desist order, Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest payments on subordinated debentures, and may not incur, increase, prepay or guarantee debt without prior written approval from the supervisors.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp"],"premise_claim_ids":["c-reg-order-limits"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Under the June 2024 cease-and-desist order, Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest payments on subordinated debentures, and may not incur, increase, prepay or guarantee debt without prior written approval from the supervisors."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-9cbd434321392d36b5a3ec96","record":{"id":"display-claim-9cbd434321392d36b5a3ec96","kind":"analysis","text":"A fintech industry newsletter reported in February 2026 that Evolve Bancorp's parent-only report for 2025 showed no operating income, a net loss of about $7.4 million, $51.1 million of long-term borrowings and $5.8 million of interest payable on subordinated debt, that the company had missed coupon payments on at least some notes, and called it functionally insolvent; that characterisation is the newsletter's, and because the retained copy of the 2025 report is a blank form the figures could not be checked against it. Under the 2024 order such interest payments need prior approval. According to correspondence the newsletter reviewed, Stifel was soliciting bids in early 2026 for two $5 million tranches of the notes, maturing in 2031 and 2032, at 40 cents on the dollar, citing the missed coupons. Director John T. Pitts Jr. is registered with Stifel in Memphis; the record shows no role for him in the offering.","source_ids":["src-035","src-003","src-102"],"entity_ids":["evolve-bancorp","stifel","john-pitts"],"premise_claim_ids":["c-fin-bancorp-distress","c-fin-bancorp-notes"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A fintech industry newsletter reported in February 2026 that Evolve Bancorp's parent-only report for 2025 showed no operating income, a net loss of about $7.4 million, $51.1 million of long-term borrowings and $5.8 million of interest payable on subordinated debt, that the company had missed coupon payments on at least some notes, and called it functionally insolvent; that characterisation is the newsletter's, and because the retained copy of the 2025 report is a blank form the figures could not be checked against it. Under the 2024 order such interest payments need prior approval. According to correspondence the newsletter reviewed, Stifel was soliciting bids in early 2026 for two $5 million tranches of the notes, maturing in 2031 and 2032, at 40 cents on the dollar, citing the missed coupons. Director John T. Pitts Jr. is registered with Stifel in Memphis; the record shows no role for him in the offering."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-cc07cfb25dde594fa3fda87a","record":{"id":"display-claim-cc07cfb25dde594fa3fda87a","kind":"analysis","text":"The Arkansas Bank Commissioner's report with data as of June 30, 2006 shows the bank, then based in Parkin, with Scot Lenoir as chairman, John Cooper as president, Scott Stafford as chief executive and Kenneth Lenoir as executive vice president; its directors were Donald Clanton, John Cooper, J. De DeHart, Scot Lenoir, Victor Saig, Scott Stafford and Stephen Valentine. By June 30, 2015 the board had nine members, Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Forrest N. Jenkins, Scot Lenoir, Lon Magness, John T. Pitts, Jr., W. Scott Stafford and Stephen Valentine, with John Copeland as chief financial officer. Jenkins, a former chairman and president of the former Citizens Bank in Marion, Arkansas, had come out of retirement to join the board and, according to his obituary, was recruited while a director to lead the bank's Arkansas Banking Division. The directors' own disclosures date Clanton's service from 2005, Pitts's from January 1, 2008 and Bright's from 2015, and a 2013 Buckeye Technologies report already described Holland as a director.","source_ids":["src-025","src-070","src-089","src-023","src-102","src-056","src-107"],"entity_ids":["evolve","scot-lenoir","john-cooper","scott-stafford","kenneth-lenoir","donald-clanton","j-de-dehart","victor-saig","steve-valentine","al-bright","lewis-holland","forrest-jenkins","lon-magness","john-pitts","john-copeland","citizens-bank-marion","bass-berry-sims","buckeye"],"premise_claim_ids":["c-brd-2006","c-brd-2015","c-brd-jenkins","c-brd-director-tenures"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Arkansas Bank Commissioner's report with data as of June 30, 2006 shows the bank, then based in Parkin, with Scot Lenoir as chairman, John Cooper as president, Scott Stafford as chief executive and Kenneth Lenoir as executive vice president; its directors were Donald Clanton, John Cooper, J. De DeHart, Scot Lenoir, Victor Saig, Scott Stafford and Stephen Valentine. By June 30, 2015 the board had nine members, Alvinor Bright, Jr., Donald Clanton, Lewis Holland, Forrest N. Jenkins, Scot Lenoir, Lon Magness, John T. Pitts, Jr., W. Scott Stafford and Stephen Valentine, with John Copeland as chief financial officer. Jenkins, a former chairman and president of the former Citizens Bank in Marion, Arkansas, had come out of retirement to join the board and, according to his obituary, was recruited while a director to lead the bank's Arkansas Banking Division. The directors' own disclosures date Clanton's service from 2005, Pitts's from January 1, 2008 and Bright's from 2015, and a 2013 Buckeye Technologies report already described Holland as a director."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-c0da187e2b5d86aef76b70cb","record":{"id":"display-claim-c0da187e2b5d86aef76b70cb","kind":"analysis","text":"In October 2021 the bank appointed Monica Wharton, then an executive of Methodist Le Bonheur Healthcare, to its board. Its 2022 annual report to the Mississippi Secretary of State listed seven directors and did not include Stafford, whom other records name as chief executive, or Wharton. The regulator's reports with data as of June 30, 2023 and 2024 list nine directors: Bright, Clanton, Holland, Lenoir, Magness, Pitts, Stafford, Valentine and Wharton, with Lenoir as chairman and Stafford as chief executive. The bank's 2024 Investor Relations kit lists eight of them, without Wharton, describing Lenoir as chief executive of Evolve Bancorp who founded the bank in 2004, Clanton as a former president of the bank's SBA Lending Division and Valentine as a director of Evolve Bancorp.","source_ids":["src-007","src-101","src-039","src-108","src-005"],"entity_ids":["evolve","monica-wharton","scot-lenoir","methodist-le-bonheur","john-freeman","henry-barham","mark-mosteller","donald-clanton","john-pitts","lewis-holland","lon-magness","steve-valentine","al-bright","scott-stafford","robin-bedsole","evolve-bancorp"],"premise_claim_ids":["c-brd-wharton-2021","c-brd-mississippi-2022","c-brd-2023-2024","c-brd-kit-2024-board"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In October 2021 the bank appointed Monica Wharton, then an executive of Methodist Le Bonheur Healthcare, to its board. Its 2022 annual report to the Mississippi Secretary of State listed seven directors and did not include Stafford, whom other records name as chief executive, or Wharton. The regulator's reports with data as of June 30, 2023 and 2024 list nine directors: Bright, Clanton, Holland, Lenoir, Magness, Pitts, Stafford, Valentine and Wharton, with Lenoir as chairman and Stafford as chief executive. The bank's 2024 Investor Relations kit lists eight of them, without Wharton, describing Lenoir as chief executive of Evolve Bancorp who founded the bank in 2004, Clanton as a former president of the bank's SBA Lending Division and Valentine as a director of Evolve Bancorp."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-7e0dfe29de9fe3d084be7418","record":{"id":"display-claim-7e0dfe29de9fe3d084be7418","kind":"analysis","text":"The report with data as of June 30, 2025 lists only six directors: Bright, Clanton, Holland, Magness, Pitts and Valentine; Lenoir, Stafford and Wharton no longer appear. The June 2024 order had been signed for Evolve Bancorp by Lenoir as chairman and for the bank by Stafford as president and chief executive, and it requires both companies to give the federal notices before appointing any director or senior executive officer and to observe the federal limits on indemnification and severance payments.","source_ids":["src-024","src-003"],"entity_ids":["evolve","al-bright","donald-clanton","lewis-holland","lon-magness","john-pitts","steve-valentine","mark-mosteller","hank-word","joelle-weltzin","scot-lenoir","scott-stafford","monica-wharton","evolve-bancorp"],"premise_claim_ids":["c-brd-2025","c-brd-fed-signatories","c-reg-order-management"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The report with data as of June 30, 2025 lists only six directors: Bright, Clanton, Holland, Magness, Pitts and Valentine; Lenoir, Stafford and Wharton no longer appear. The June 2024 order had been signed for Evolve Bancorp by Lenoir as chairman and for the bank by Stafford as president and chief executive, and it requires both companies to give the federal notices before appointing any director or senior executive officer and to observe the federal limits on indemnification and severance payments."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-b45b3ed2de3094a4cb0e0f5a","record":{"id":"display-claim-b45b3ed2de3094a4cb0e0f5a","kind":"analysis","text":"The 2023 kit named Robert Ducklo as general counsel and corporate secretary, Cecilia Russell as chief compliance officer and Robin Bedsole as controller. In the 2024 kit, senior management comprised Mark Mosteller (chief financial officer, at the bank since 2015), Joelle Weltzin (general counsel), Hank Word (president of Open Banking, who joined in 2014 as the bank's first chief technology officer), W. Christopher Staab (chief technology officer), Peter Moenickheim (chief risk officer, whose appointment the bank notified to the Federal Reserve in early 2024), Thomas E. Holmes, Jr. (marketing and communications), John C. Freeman (president of the Banking Division, a former president of Liberty Bank in Jonesboro and chairman of the Arkansas Bankers Association board) and Randy Reynolds (Arkansas Banking Division). Holmes later announced that he was stepping away, citing 'significant personal and professional challenges'; an online encyclopedia dates his resignation to October 2024.","source_ids":["src-020","src-005","src-019","src-070","src-048","src-004"],"entity_ids":["evolve","monica-wharton","robert-ducklo","cecilia-russell","robin-bedsole","methodist-le-bonheur","mark-mosteller","joelle-weltzin","hank-word","christopher-staab","peter-moenickheim","thomas-holmes","john-freeman","randy-reynolds","liberty-bank","arkansas-bankers-association"],"premise_claim_ids":["c-brd-kit-2023","c-brd-kit-2024-management","c-brd-cro-notice","c-brd-freeman","c-brd-holmes"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The 2023 kit named Robert Ducklo as general counsel and corporate secretary, Cecilia Russell as chief compliance officer and Robin Bedsole as controller. In the 2024 kit, senior management comprised Mark Mosteller (chief financial officer, at the bank since 2015), Joelle Weltzin (general counsel), Hank Word (president of Open Banking, who joined in 2014 as the bank's first chief technology officer), W. Christopher Staab (chief technology officer), Peter Moenickheim (chief risk officer, whose appointment the bank notified to the Federal Reserve in early 2024), Thomas E. Holmes, Jr. (marketing and communications), John C. Freeman (president of the Banking Division, a former president of Liberty Bank in Jonesboro and chairman of the Arkansas Bankers Association board) and Randy Reynolds (Arkansas Banking Division). Holmes later announced that he was stepping away, citing 'significant personal and professional challenges'; an online encyclopedia dates his resignation to October 2024."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ad09914deaf4dcd48024c99c","record":{"id":"display-claim-ad09914deaf4dcd48024c99c","kind":"analysis","text":"According to a fintech industry newsletter, Lenoir, chairman for 20 years, stepped down from the chair in July 2024 and now describes himself as the bank's founder. An internal memo reported by the newsletter in February 2025 made Mosteller president while he kept the finance role, replacing Stafford, who had decided to step away from day-to-day operations, and promoted Word and Weltzin, the latter having joined in March 2024, to executive vice president. A business-profile aggregator says Stafford retired in 2025. In August 2025 the board, chaired by Valentine, unanimously appointed Robert Hartheimer chief executive, with Mosteller, Word and Weltzin keeping their roles. Word left in September 2025; the newsletter's sources said he resigned voluntarily. His public professional profile lists TabaPay, one of the bank's Open Banking partners, as his current company.","source_ids":["src-011","src-024","src-008","src-098","src-004","src-026","src-100"],"entity_ids":["scot-lenoir","evolve","mark-mosteller","scott-stafford","hank-word","joelle-weltzin","robert-hartheimer","steve-valentine","tabapay"],"premise_claim_ids":["c-brd-lenoir-steps-down","c-brd-feb-2025-memo","c-brd-stafford-retired","c-brd-hartheimer-appointed","c-brd-word-leaves","c-ppl-word-tabapay"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to a fintech industry newsletter, Lenoir, chairman for 20 years, stepped down from the chair in July 2024 and now describes himself as the bank's founder. An internal memo reported by the newsletter in February 2025 made Mosteller president while he kept the finance role, replacing Stafford, who had decided to step away from day-to-day operations, and promoted Word and Weltzin, the latter having joined in March 2024, to executive vice president. A business-profile aggregator says Stafford retired in 2025. In August 2025 the board, chaired by Valentine, unanimously appointed Robert Hartheimer chief executive, with Mosteller, Word and Weltzin keeping their roles. Word left in September 2025; the newsletter's sources said he resigned voluntarily. His public professional profile lists TabaPay, one of the bank's Open Banking partners, as his current company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-f4af3b2f60de3762a3ad232c","record":{"id":"display-claim-f4af3b2f60de3762a3ad232c","kind":"analysis","text":"Alex Johnston became head of Open Banking on October 2, 2025. After Hartheimer's dismissal later that month, the bank said its executive leadership team of Mosteller and Weltzin would oversee operations and strategy as before August, and in February 2026 it named Arlon Duke chief technology officer. The retained copy of the bank's news page shows no announcement of a new chief executive, which does not exclude an announcement elsewhere.","source_ids":["src-053","src-014","src-097","src-114"],"entity_ids":["evolve","alex-johnston","robert-hartheimer","mark-mosteller","joelle-weltzin","arlon-duke"],"premise_claim_ids":["c-brd-johnston","c-brd-after-hartheimer","c-brd-no-new-ceo"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Alex Johnston became head of Open Banking on October 2, 2025. After Hartheimer's dismissal later that month, the bank said its executive leadership team of Mosteller and Weltzin would oversee operations and strategy as before August, and in February 2026 it named Arlon Duke chief technology officer. The retained copy of the bank's news page shows no announcement of a new chief executive, which does not exclude an announcement elsewhere."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-553ff7aaa196d7b80cc132ea","record":{"id":"display-claim-553ff7aaa196d7b80cc132ea","kind":"analysis","text":"Stephen Valentine advises companies in distribution, consumer and technology industries and was earlier an IBM executive and AutoZone's chief information officer. Donald B. Clanton retired in 2017 as chief operating officer of the broker-dealer Duncan-Williams and earlier ran Commerce Investment Corporation, a National Bank of Commerce subsidiary; his BrokerCheck record shows no disclosed complaints or regulatory events. Al Bright, Jr. is a member of the law firm Bass, Berry & Sims and, in 2025, vice chairman of Evolve Bancorp. Lon M. Magness is a principal and the chief compliance officer of Reliant Investment Management. John T. Pitts Jr. has been registered with Stifel, Nicolaus & Company in Memphis since 2015, with no disclosures, after serving as executive vice president of National Bank of Commerce's capital-markets group.","source_ids":["src-005","src-023","src-056","src-024","src-057","src-102"],"entity_ids":["steve-valentine","evolve-bancorp","ibm","autozone","donald-clanton","evolve","duncan-williams","commerce-investment-corp","national-bank-of-commerce","al-bright","bass-berry-sims","lon-magness","reliant-investment-management","john-pitts","stifel"],"premise_claim_ids":["c-ppl-valentine","c-ppl-clanton","c-ppl-bright","c-ppl-magness","c-ppl-pitts"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Stephen Valentine advises companies in distribution, consumer and technology industries and was earlier an IBM executive and AutoZone's chief information officer. Donald B. Clanton retired in 2017 as chief operating officer of the broker-dealer Duncan-Williams and earlier ran Commerce Investment Corporation, a National Bank of Commerce subsidiary; his BrokerCheck record shows no disclosed complaints or regulatory events. Al Bright, Jr. is a member of the law firm Bass, Berry & Sims and, in 2025, vice chairman of Evolve Bancorp. Lon M. Magness is a principal and the chief compliance officer of Reliant Investment Management. John T. Pitts Jr. has been registered with Stifel, Nicolaus & Company in Memphis since 2015, with no disclosures, after serving as executive vice president of National Bank of Commerce's capital-markets group."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-12cf16b97cbb549fcd57f34e","record":{"id":"display-claim-12cf16b97cbb549fcd57f34e","kind":"analysis","text":"Lewis E. Holland is a director of Raymond James Financial Products, a Tennessee company in the Raymond James group, and of USI Alliance, a Memphis leasing and community-development company that SunTrust applied to acquire in its 2004 merger with National Commerce Financial; he was president of the Henry Turley Company from 2001 to 2009, earlier vice chairman and chief financial officer of National Commerce Bancorporation, and a Buckeye Technologies director from 2005 to 2013. Before joining Evolve, Scott Stafford was a senior vice president of National Bank of Commerce and an investment banker at Duncan-Williams. Mark Mosteller came from GTx, Inc., where he was chief financial officer, and earlier was chief operating officer of Union Planters Mortgage. Monica Wharton is executive vice president and chief operating officer of Methodist Le Bonheur Healthcare and was earlier chief legal officer of Regional One Health.","source_ids":["src-107","src-005","src-105","src-106","src-099"],"entity_ids":["lewis-holland","raymond-james-financial-products","usi-alliance","henry-turley","national-commerce-financial","buckeye","suntrust-banks","scott-stafford","national-bank-of-commerce","duncan-williams","mark-mosteller","evolve","gtx","union-planters-mortgage","monica-wharton","methodist-le-bonheur","regional-one-health"],"premise_claim_ids":["c-ppl-holland","c-ppl-holland-companies","c-ppl-stafford","c-ppl-mosteller","c-ppl-wharton"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Lewis E. Holland is a director of Raymond James Financial Products, a Tennessee company in the Raymond James group, and of USI Alliance, a Memphis leasing and community-development company that SunTrust applied to acquire in its 2004 merger with National Commerce Financial; he was president of the Henry Turley Company from 2001 to 2009, earlier vice chairman and chief financial officer of National Commerce Bancorporation, and a Buckeye Technologies director from 2005 to 2013. Before joining Evolve, Scott Stafford was a senior vice president of National Bank of Commerce and an investment banker at Duncan-Williams. Mark Mosteller came from GTx, Inc., where he was chief financial officer, and earlier was chief operating officer of Union Planters Mortgage. Monica Wharton is executive vice president and chief operating officer of Methodist Le Bonheur Healthcare and was earlier chief legal officer of Regional One Health."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-049a1acf2453a4cb5d8fd496","record":{"id":"display-claim-049a1acf2453a4cb5d8fd496","kind":"analysis","text":"According to the bank's 2024 kit, B. Scot Lenoir rose to chief executive and president of First Mercantile Trust Company, a financial institution with more than $3 billion in assets, and arranged its sale to a publicly traded company; after the sale in 2000 he raised the initial capital for Evolve Bancorp, of which he is founder and chief executive. The Federal Reserve approved National Commerce Bancorporation's acquisition of FMT Holding Company on June 20, 2000, and a regional business publication reported in 2005 that his family had sold First Mercantile Trust, which managed more than $3 billion of pension and profit-sharing assets, to National Commerce Bancorp. In 2004 SunTrust, merging with National Commerce Financial, applied to acquire First Mercantile Trust Company of Memphis. A fintech industry newsletter describes First Mercantile as the firm of Lenoir's father, Kenneth Lenoir, who in 2006 was also listed as an executive vice president of Evolve Bank & Trust.","source_ids":["src-005","src-033","src-093","src-106","src-015","src-025"],"entity_ids":["scot-lenoir","first-mercantile","evolve-bancorp","national-commerce-financial","suntrust-banks","kenneth-lenoir","evolve"],"premise_claim_ids":["c-fnd-lenoir-bio","c-fnd-fmt-sale","c-fnd-kenneth"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the bank's 2024 kit, B. Scot Lenoir rose to chief executive and president of First Mercantile Trust Company, a financial institution with more than $3 billion in assets, and arranged its sale to a publicly traded company; after the sale in 2000 he raised the initial capital for Evolve Bancorp, of which he is founder and chief executive. The Federal Reserve approved National Commerce Bancorporation's acquisition of FMT Holding Company on June 20, 2000, and a regional business publication reported in 2005 that his family had sold First Mercantile Trust, which managed more than $3 billion of pension and profit-sharing assets, to National Commerce Bancorp. In 2004 SunTrust, merging with National Commerce Financial, applied to acquire First Mercantile Trust Company of Memphis. A fintech industry newsletter describes First Mercantile as the firm of Lenoir's father, Kenneth Lenoir, who in 2006 was also listed as an executive vice president of Evolve Bank & Trust."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-72bea6b411c31ff8c5a65e1a","record":{"id":"display-claim-72bea6b411c31ff8c5a65e1a","kind":"analysis","text":"In December 2002 Corky's Bar-B-Q and its owners sued National Bank of Commerce and First Mercantile Trust, both subsidiaries of National Commerce Financial, together with First Mercantile's chief executive Kenneth Lenoir and its president Bryan Scot Lenoir, alleging breaches of fiduciary duty and racketeering through undisclosed fees on 401(k) plans and seeking $700 million. These are the plaintiffs' allegations as reported by the press, not findings, and the complaint itself was not retained. National Commerce Financial said the suit contained 'grossly inaccurate assertions' and 'grossly exaggerated damages' and that the parties would vigorously defend it, and a First Mercantile spokesman denied the complaint's statement that Kenneth Lenoir had been terminated. A fintech industry newsletter later reported that the suit was settled for $18 million; no settlement document was retained. The newsletter also reports that First Mercantile and Kenneth Lenoir were named in an earlier pension-plan case that was dismissed after the parties settled.","source_ids":["src-095","src-015","src-111","src-025"],"entity_ids":["corkys","first-mercantile","national-bank-of-commerce","national-commerce-financial","kenneth-lenoir","scot-lenoir","evolve"],"premise_claim_ids":["c-fnd-corkys-suit","c-fnd-kenneth"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In December 2002 Corky's Bar-B-Q and its owners sued National Bank of Commerce and First Mercantile Trust, both subsidiaries of National Commerce Financial, together with First Mercantile's chief executive Kenneth Lenoir and its president Bryan Scot Lenoir, alleging breaches of fiduciary duty and racketeering through undisclosed fees on 401(k) plans and seeking $700 million. These are the plaintiffs' allegations as reported by the press, not findings, and the complaint itself was not retained. National Commerce Financial said the suit contained 'grossly inaccurate assertions' and 'grossly exaggerated damages' and that the parties would vigorously defend it, and a First Mercantile spokesman denied the complaint's statement that Kenneth Lenoir had been terminated. A fintech industry newsletter later reported that the suit was settled for $18 million; no settlement document was retained. The newsletter also reports that First Mercantile and Kenneth Lenoir were named in an earlier pension-plan case that was dismissed after the parties settled."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-d329409b5c306e9fe2804445","record":{"id":"display-claim-d329409b5c306e9fe2804445","kind":"analysis","text":"Lenoir organised Evolve Financial Group, formed in January 2004, which in 2005 sought to buy Parkin Bancorp, the holding company of First State Bank. A financial-data aggregator lists him as founder, chairman, president and chief executive of Evolve Financial Group and of Evolve Bancorp, former chairman of the bank, and former head of American Trust Co. (Tennessee) and AFS Investment Advisors; those last two roles are undated and do not appear in the other retained records. He chaired the bank for about 20 years; a fintech industry newsletter reported in February 2025 that he had left the chair in July 2024 and now called himself founder, and a bank spokesperson told the newsletter he remained involved in day-to-day operations. In October 2024 he spoke for the bank as its founder when it announced payments to Synapse Brokerage end users, criticising 'the flawed ledgers from Synapse'.","source_ids":["src-033","src-055","src-011","src-024","src-038","src-008"],"entity_ids":["evolve-financial-group","evolve-bancorp","scot-lenoir","evolve","american-trust-co","afs-investment-advisors","rust-consulting","synapse-brokerage","ankura"],"premise_claim_ids":["c-grp-2005-purchase","c-fnd-lenoir-other-roles","c-brd-lenoir-steps-down","c-rec-rust"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Lenoir organised Evolve Financial Group, formed in January 2004, which in 2005 sought to buy Parkin Bancorp, the holding company of First State Bank. A financial-data aggregator lists him as founder, chairman, president and chief executive of Evolve Financial Group and of Evolve Bancorp, former chairman of the bank, and former head of American Trust Co. (Tennessee) and AFS Investment Advisors; those last two roles are undated and do not appear in the other retained records. He chaired the bank for about 20 years; a fintech industry newsletter reported in February 2025 that he had left the chair in July 2024 and now called himself founder, and a bank spokesperson told the newsletter he remained involved in day-to-day operations. In October 2024 he spoke for the bank as its founder when it announced payments to Synapse Brokerage end users, criticising 'the flawed ledgers from Synapse'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-4c683515e7c84af45a954748","record":{"id":"display-claim-4c683515e7c84af45a954748","kind":"analysis","text":"A published database of offshore-company records, using leaked records and Barbados registry data, lists Evolve Assignments Ltd., incorporated in Barbados on May 26, 2009, with six directors including persons recorded as 'Lenoir Bryan Scott' and 'Stafford William Scott', both from May 26, 2009 to September 10, 2014. The database gives no address, date of birth or other identifier for them, so the record does not establish whether they are the bank's founder and its former chief executive; the database's publisher states that many people share names and that inclusion does not suggest illegal or improper conduct. No other retained record mentions the company.","source_ids":["src-022","src-021"],"entity_ids":["evolve-assignments","scot-lenoir","scott-stafford"],"premise_claim_ids":["c-offshore-evolve-assignments"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A published database of offshore-company records, using leaked records and Barbados registry data, lists Evolve Assignments Ltd., incorporated in Barbados on May 26, 2009, with six directors including persons recorded as 'Lenoir Bryan Scott' and 'Stafford William Scott', both from May 26, 2009 to September 10, 2014. The database gives no address, date of birth or other identifier for them, so the record does not establish whether they are the bank's founder and its former chief executive; the database's publisher states that many people share names and that inclusion does not suggest illegal or improper conduct. No other retained record mentions the company."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ca8e81a9a4b170ab492109d1","record":{"id":"display-claim-ca8e81a9a4b170ab492109d1","kind":"analysis","text":"Robert H. Hartheimer joined the FDIC in 1991, helped create its Division of Resolutions and later directed it. He was a managing director of Promontory Financial Group from 2002 to 2008, co-founder and chief regulatory officer of the credit-card originator CreditStacks (Jasper) from 2015 to 2020, and later a senior adviser at the advisory and investment firm Klaros. Repay Holdings' 2021 proxy statement lists him as a Repay director since June 2018, a director and audit-committee chairman of Thunder Bridge Capital Partners III since February 2021, an independent director of the consumer lender and card servicer CardWorks since 2017, an organiser and director nominee of Monzo US from December 2019 and, since 2008, founder and managing member of the consultancy Hartheimer LLC, with earlier seats at Thunder Bridge Acquisition II, Lending Club Asset Management and Higher One Holdings. The bank's announcement of his appointment said he had been a corporate director of ten companies.","source_ids":["src-008","src-054"],"entity_ids":["robert-hartheimer","klaros","jasper","promontory","fdic","evolve","repay","thunder-bridge-iii","cardworks","monzo-us","hartheimer-llc","thunder-bridge-ii","lending-club-am","higher-one"],"premise_claim_ids":["c-ppl-hartheimer-career","c-ppl-hartheimer-boards"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Robert H. Hartheimer joined the FDIC in 1991, helped create its Division of Resolutions and later directed it. He was a managing director of Promontory Financial Group from 2002 to 2008, co-founder and chief regulatory officer of the credit-card originator CreditStacks (Jasper) from 2015 to 2020, and later a senior adviser at the advisory and investment firm Klaros. Repay Holdings' 2021 proxy statement lists him as a Repay director since June 2018, a director and audit-committee chairman of Thunder Bridge Capital Partners III since February 2021, an independent director of the consumer lender and card servicer CardWorks since 2017, an organiser and director nominee of Monzo US from December 2019 and, since 2008, founder and managing member of the consultancy Hartheimer LLC, with earlier seats at Thunder Bridge Acquisition II, Lending Club Asset Management and Higher One Holdings. The bank's announcement of his appointment said he had been a corporate director of ten companies."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-c736c8cf08c39820f7cac1f3","record":{"id":"display-claim-c736c8cf08c39820f7cac1f3","kind":"analysis","text":"On August 13, 2025 the bank's board unanimously chose him as chief executive with immediate effect; chairman Steve Valentine called it 'a turning point for Evolve'. In early October the bank announced Alex Johnston as head of Open Banking, quoting Hartheimer. A regional business publication reported on October 27, 2025 that the bank had lost $8.76 million in the first half of 2025 and that Hartheimer, who had taken over that summer, said losses would continue into the next year while the bank installed guardrails against a repeat of the problems behind the federal enforcement actions.","source_ids":["src-004","src-008","src-053","src-112"],"entity_ids":["evolve","robert-hartheimer","steve-valentine","mark-mosteller","hank-word","joelle-weltzin","alex-johnston"],"premise_claim_ids":["c-brd-hartheimer-appointed","c-brd-johnston","c-fin-h1-2025"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On August 13, 2025 the bank's board unanimously chose him as chief executive with immediate effect; chairman Steve Valentine called it 'a turning point for Evolve'. In early October the bank announced Alex Johnston as head of Open Banking, quoting Hartheimer. A regional business publication reported on October 27, 2025 that the bank had lost $8.76 million in the first half of 2025 and that Hartheimer, who had taken over that summer, said losses would continue into the next year while the bank installed guardrails against a repeat of the problems behind the federal enforcement actions."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-087729927be2e86a847113c2","record":{"id":"display-claim-087729927be2e86a847113c2","kind":"analysis","text":"On October 23, 2025 FBI agents arrested Hartheimer at the bank's Memphis headquarters under a court-authorised warrant. A local television station, citing the FBI, reported that he faced charges of sexual exploitation of a minor and distribution of obscene material; the criminal complaint, filed under seal on October 24, 2025, is not in the retained record. The board said it was treating the matter with the utmost seriousness and had terminated him with immediate effect; the bank said the matter was personal and unrelated to the bank or its operations, that it was in close contact with the U.S. Attorney's office and had offered its full cooperation. Mosteller and Weltzin resumed running the bank.","source_ids":["src-006","src-004","src-072","src-014","src-097"],"entity_ids":["robert-hartheimer","evolve","mark-mosteller","joelle-weltzin","arlon-duke"],"premise_claim_ids":["c-ceo-arrest","c-ceo-dismissal","c-brd-after-hartheimer"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On October 23, 2025 FBI agents arrested Hartheimer at the bank's Memphis headquarters under a court-authorised warrant. A local television station, citing the FBI, reported that he faced charges of sexual exploitation of a minor and distribution of obscene material; the criminal complaint, filed under seal on October 24, 2025, is not in the retained record. The board said it was treating the matter with the utmost seriousness and had terminated him with immediate effect; the bank said the matter was personal and unrelated to the bank or its operations, that it was in close contact with the U.S. Attorney's office and had offered its full cooperation. Mosteller and Weltzin resumed running the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-f09792d412e92b46b58ca023","record":{"id":"display-claim-f09792d412e92b46b58ca023","kind":"analysis","text":"In United States v. Hartheimer (W.D. Tenn. No. 2:25-cr-20314) a two-count criminal information was filed on December 15, 2025. On January 5, 2026 he waived indictment and pleaded guilty to both counts before Chief Judge Sheryl H. Lipman under a written plea agreement, and was remanded into custody. On June 4, 2026 the court sentenced him to 51 months in prison followed by five years of supervised release with specialised sex-offender conditions, a $200 special assessment and two $10,000 assessments under federal victim-assistance laws. On July 2, 2026 the United States filed a notice of appeal. The retained docket does not describe the statutes of conviction or the grounds of the government's appeal.","source_ids":["src-072","src-006","src-004","src-014"],"entity_ids":["robert-hartheimer","evolve"],"premise_claim_ids":["c-ceo-plea","c-ceo-sentence","c-ceo-arrest"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In United States v. Hartheimer (W.D. Tenn. No. 2:25-cr-20314) a two-count criminal information was filed on December 15, 2025. On January 5, 2026 he waived indictment and pleaded guilty to both counts before Chief Judge Sheryl H. Lipman under a written plea agreement, and was remanded into custody. On June 4, 2026 the court sentenced him to 51 months in prison followed by five years of supervised release with specialised sex-offender conditions, a $200 special assessment and two $10,000 assessments under federal victim-assistance laws. On July 2, 2026 the United States filed a notice of appeal. The retained docket does not describe the statutes of conviction or the grounds of the government's appeal."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ea2580bb627a3df810bd97f9","record":{"id":"display-claim-ea2580bb627a3df810bd97f9","kind":"analysis","text":"Evolve started its Open Banking business in 2017, offering fintech partners API banking so that they could build its banking services into their own platforms, and later added payment processing, compliance management and lending services. The Federal Reserve's 2024 order describes the strategy as offering deposit accounts and payment processing to fintech partners, which in turn offer financial products to end users. In its 2024 Investor Relations kit the bank says fintech apps can issue 'vAccounts' to users while Evolve holds the funds in its 'stored value ecosystem'; it cites principal membership of Visa and Mastercard and $8 billion of total bank and custodial assets, undated marketing figures that include custodial assets outside the balance sheet. Senators noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later.","source_ids":["src-012","src-004","src-003","src-005","src-020","src-031"],"entity_ids":["evolve","branch","marqeta","mercury","stripe","visa","mastercard"],"premise_claim_ids":["c-baas-origin","c-reg-order-baas","c-baas-vaccounts","c-fin-growth-2019-2022"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve started its Open Banking business in 2017, offering fintech partners API banking so that they could build its banking services into their own platforms, and later added payment processing, compliance management and lending services. The Federal Reserve's 2024 order describes the strategy as offering deposit accounts and payment processing to fintech partners, which in turn offer financial products to end users. In its 2024 Investor Relations kit the bank says fintech apps can issue 'vAccounts' to users while Evolve holds the funds in its 'stored value ecosystem'; it cites principal membership of Visa and Mastercard and $8 billion of total bank and custodial assets, undated marketing figures that include custodial assets outside the balance sheet. Senators noted that the bank's assets grew from $451 million at the end of 2019 to $1.75 billion three years later."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-e3152987e18fc506b367e4c9","record":{"id":"display-claim-e3152987e18fc506b367e4c9","kind":"analysis","text":"The account terms that partners publish show how customers' money can move. Under the agreement published by Sila, the customer appoints the bank as agent to place funds at its discretion in a deposit or omnibus custody 'Sub-Deposit Account' in the bank's name, in its Trust Department or at other insured banks, with ownership recorded only in the bank's books; Dwolla's version of the terms, last updated August 1, 2021, adds that the other bank's records are in Evolve's name as agent or custodian. B9's 2026 agreement places customers in a 'Bank Deposit Custodial Program' whose sub-deposit accounts are obligations of the program banks, not of Evolve or B9. Melio holds master accounts at Evolve and other banks titled for the benefit of its customers and instructs the banks on moving the funds.","source_ids":["src-045","src-085","src-061","src-073"],"entity_ids":["evolve","sila","dwolla","b9","melio"],"premise_claim_ids":["c-baas-sub-deposit","c-baas-dwolla","c-baas-b9-custodial","c-baas-melio-fbo"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The account terms that partners publish show how customers' money can move. Under the agreement published by Sila, the customer appoints the bank as agent to place funds at its discretion in a deposit or omnibus custody 'Sub-Deposit Account' in the bank's name, in its Trust Department or at other insured banks, with ownership recorded only in the bank's books; Dwolla's version of the terms, last updated August 1, 2021, adds that the other bank's records are in Evolve's name as agent or custodian. B9's 2026 agreement places customers in a 'Bank Deposit Custodial Program' whose sub-deposit accounts are obligations of the program banks, not of Evolve or B9. Melio holds master accounts at Evolve and other banks titled for the benefit of its customers and instructs the banks on moving the funds."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-99757b67e78b1df200760b6d","record":{"id":"display-claim-99757b67e78b1df200760b6d","kind":"analysis","text":"Dave Inc. has had a Bank Services Agreement with Evolve since July 13, 2020, under which the bank issues and maintains deposit accounts and sponsors debit and ACH access while Dave keeps the ledger needed for pass-through deposit insurance. Affirm says Evolve is the single issuing bank for the Affirm Card under a loan program agreement that renews each year. Marqeta announced a partnership in 2022 for card programmes, although its 2025 report names Sutton Bank, not Evolve, as its main issuing bank. Stripe says Stripe Treasury funds are held at Evolve and Goldman Sachs Bank USA, and the fintech Arc described start-ups' funds held in treasury accounts at Evolve. Airwallex's U.S. agreement lets Evolve provide domestic payment services to Airwallex customers, Branch's Branch Account has included an Evolve deposit account since January 2020, and EarnIn's Early Pay requires a deposit account at Evolve or Lead Bank. Usio used Evolve as sponsor bank for PINless debit processing from 2018 until TransPecos Bank took over in 2023.","source_ids":["src-041","src-042","src-034","src-046","src-051","src-076","src-092","src-091","src-071","src-090","src-067","src-074","src-049"],"entity_ids":["dave","evolve","dave-operating","affirm","marqeta","hank-word","stripe","arc","airwallex","branch","earnin","usio"],"premise_claim_ids":["c-baas-dave-agreement","c-baas-affirm","c-baas-marqeta","c-baas-stripe-arc","c-baas-airwallex","c-baas-branch","c-baas-earnin","c-baas-usio"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Dave Inc. has had a Bank Services Agreement with Evolve since July 13, 2020, under which the bank issues and maintains deposit accounts and sponsors debit and ACH access while Dave keeps the ledger needed for pass-through deposit insurance. Affirm says Evolve is the single issuing bank for the Affirm Card under a loan program agreement that renews each year. Marqeta announced a partnership in 2022 for card programmes, although its 2025 report names Sutton Bank, not Evolve, as its main issuing bank. Stripe says Stripe Treasury funds are held at Evolve and Goldman Sachs Bank USA, and the fintech Arc described start-ups' funds held in treasury accounts at Evolve. Airwallex's U.S. agreement lets Evolve provide domestic payment services to Airwallex customers, Branch's Branch Account has included an Evolve deposit account since January 2020, and EarnIn's Early Pay requires a deposit account at Evolve or Lead Bank. Usio used Evolve as sponsor bank for PINless debit processing from 2018 until TransPecos Bank took over in 2023."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-fdf8a93f6b0e42df3d05c0b4","record":{"id":"display-claim-fdf8a93f6b0e42df3d05c0b4","kind":"analysis","text":"The bank's own lists changed over time. Its 2023 kit showed Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold; the 2024 kit showed Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio; and the partnerships page in the retained website copy lists Airwallex, Affirm, Branch, EarnIn, Flute, Luqra, Marqeta, Mastercard, Melio, Netevia, Rain, Split Pay, Step, TabaPay, Visa and VIVA Finance, without distinguishing card networks, programme managers and fintech programmes. Its news page lists an item on Coinstar expanding a transfer-to-account service with TabaPay and Evolve.","source_ids":["src-020","src-005","src-043","src-114"],"entity_ids":["evolve","branch","earnin","melio","prizepool","sila","stripe","uphold","affirm","airwallex","bond","dave","marqeta","flute","luqra","mastercard","netevia","rain","split-pay","step","tabapay","visa","viva-finance","coinstar"],"premise_claim_ids":["c-baas-partners-2023","c-baas-partners-2024","c-baas-partners-site","c-baas-coinstar"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The bank's own lists changed over time. Its 2023 kit showed Branch, EarnIn, Melio, Prizepool, Sila, Stripe and Uphold; the 2024 kit showed Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio; and the partnerships page in the retained website copy lists Airwallex, Affirm, Branch, EarnIn, Flute, Luqra, Marqeta, Mastercard, Melio, Netevia, Rain, Split Pay, Step, TabaPay, Visa and VIVA Finance, without distinguishing card networks, programme managers and fintech programmes. Its news page lists an item on Coinstar expanding a transfer-to-account service with TabaPay and Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-9ffdaa01569a28b42c716131","record":{"id":"display-claim-9ffdaa01569a28b42c716131","kind":"analysis","text":"A fintech industry newsletter reported in February 2026 that major programmes, including Mercury and Dave, had left the bank, cutting its deposit and referral fee revenue by 66%, and that the teen app Step, the cash-advance app B9 and the middleware platform Mbanq still worked with it; Mercury had announced in March 2025 that it would move customers to Column N.A. and Choice Financial Group. A bank spokesperson told a business magazine in March 2025 that Evolve remained focused on strengthening existing relationships and exploring new ones with established fintechs. Dave's 2025 report says all new members are opened at Coastal Community Bank and that it expected substantially to finish moving existing members there by the end of 2026, though most accounts were still at Evolve.","source_ids":["src-035","src-050","src-096","src-041"],"entity_ids":["evolve","mercury","dave","step","b9","mbanq","coastal-community-bank"],"premise_claim_ids":["c-baas-departures","c-baas-dave-exit"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A fintech industry newsletter reported in February 2026 that major programmes, including Mercury and Dave, had left the bank, cutting its deposit and referral fee revenue by 66%, and that the teen app Step, the cash-advance app B9 and the middleware platform Mbanq still worked with it; Mercury had announced in March 2025 that it would move customers to Column N.A. and Choice Financial Group. A bank spokesperson told a business magazine in March 2025 that Evolve remained focused on strengthening existing relationships and exploring new ones with established fintechs. Dave's 2025 report says all new members are opened at Coastal Community Bank and that it expected substantially to finish moving existing members there by the end of 2026, though most accounts were still at Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-4080dc2d03d619d0544ea5e1","record":{"id":"display-claim-4080dc2d03d619d0544ea5e1","kind":"analysis","text":"On April 29, 2026 Coastal Community Bank signed a non-binding term sheet with Evolve to acquire the assets and deposits of a diverse set of its BaaS programmes, subject to due diligence, definitive agreements and regulatory approval. On Coastal's July 30, 2026 earnings call, according to a market-news summary, its chief executive said it was no longer actively pursuing the acquisition.","source_ids":["src-028","src-119"],"entity_ids":["coastal-community-bank","evolve"],"premise_claim_ids":["c-baas-coastal"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On April 29, 2026 Coastal Community Bank signed a non-binding term sheet with Evolve to acquire the assets and deposits of a diverse set of its BaaS programmes, subject to due diligence, definitive agreements and regulatory approval. On Coastal's July 30, 2026 earnings call, according to a market-news summary, its chief executive said it was no longer actively pursuing the acquisition."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-397cd422c16638320f7855a6","record":{"id":"display-claim-397cd422c16638320f7855a6","kind":"analysis","text":"In April 2025 a putative class of Dave customers sued Dave and Evolve in Los Angeles, alleging violations of the Military Lending Act and the Truth in Lending Act; after the federal court refused to dismiss the case or compel arbitration, Dave and Evolve jointly appealed to the Ninth Circuit in December 2025 and the case was stayed. These are the plaintiffs' allegations, with no ruling on the merits. In December 2024 the CFPB sued Walmart and Branch over Branch Accounts, which include an Evolve deposit account, opened for delivery drivers; Evolve is not a defendant. Senators wrote in 2025 that Evolve had also partnered with SoLo Funds and Branch, two fintechs sued by the CFPB.","source_ids":["src-041","src-094","src-067","src-031"],"entity_ids":["dave","evolve","cfpb","branch","solo-funds"],"premise_claim_ids":["c-lit-dave","c-lit-branch-cfpb","c-baas-solo-branch"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In April 2025 a putative class of Dave customers sued Dave and Evolve in Los Angeles, alleging violations of the Military Lending Act and the Truth in Lending Act; after the federal court refused to dismiss the case or compel arbitration, Dave and Evolve jointly appealed to the Ninth Circuit in December 2025 and the case was stayed. These are the plaintiffs' allegations, with no ruling on the merits. In December 2024 the CFPB sued Walmart and Branch over Branch Accounts, which include an Evolve deposit account, opened for delivery drivers; Evolve is not a defendant. Senators wrote in 2025 that Evolve had also partnered with SoLo Funds and Branch, two fintechs sued by the CFPB."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-2a46884b4b48f61571388756","record":{"id":"display-claim-2a46884b4b48f61571388756","kind":"analysis","text":"Synapse Financial Technologies, a Delaware company based in Woodland Hills, California, founded and run by Sankaet Pathak, provided technology and other services to fintech platforms and partner banks. According to the CFPB's 2025 complaint, Evolve was one of its partner banks: they signed a Bank Services Agreement around April 18, 2017 and a Master Bank Services Agreement around September 23, 2022, and until at least summer 2023 Synapse gave consumers who opened accounts through fintech platforms a deposit account agreement on Evolve's behalf.","source_ids":["src-029","src-052"],"entity_ids":["synapse","sankaet-pathak","synapse-brokerage","evolve","cfpb"],"premise_claim_ids":["c-syn-company","c-syn-agreements"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Synapse Financial Technologies, a Delaware company based in Woodland Hills, California, founded and run by Sankaet Pathak, provided technology and other services to fintech platforms and partner banks. According to the CFPB's 2025 complaint, Evolve was one of its partner banks: they signed a Bank Services Agreement around April 18, 2017 and a Master Bank Services Agreement around September 23, 2022, and until at least summer 2023 Synapse gave consumers who opened accounts through fintech platforms a deposit account agreement on Evolve's behalf."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-8767ecdeed8559a41c1c34d0","record":{"id":"display-claim-8767ecdeed8559a41c1c34d0","kind":"analysis","text":"FINRA's August 2025 complaint against two former officers of Synapse's brokerage describes the structure without naming the bank, calling it 'DDA Bank 1'; a fintech industry newsletter identified it as apparently Evolve, and the account matches the CFPB complaint, which names Evolve. End users who opened accounts through fintechs deposited money with the bank, where before December 2023 it sat in omnibus accounts in the bank's name for their benefit; the bank kept ledgers only at the omnibus level and relied on Synapse for individual balances. Its services agreement with Synapse expired in September 2023, with a wind-down to May 2024. These are FINRA's allegations against the two officers, not findings about the bank.","source_ids":["src-027","src-026"],"entity_ids":["evolve","synapse","finra"],"premise_claim_ids":["c-syn-structure"],"qualification":"","response":"","outcome":""},"reading":"Analysis: FINRA's August 2025 complaint against two former officers of Synapse's brokerage describes the structure without naming the bank, calling it 'DDA Bank 1'; a fintech industry newsletter identified it as apparently Evolve, and the account matches the CFPB complaint, which names Evolve. End users who opened accounts through fintechs deposited money with the bank, where before December 2023 it sat in omnibus accounts in the bank's name for their benefit; the bank kept ledgers only at the omnibus level and relied on Synapse for individual balances. Its services agreement with Synapse expired in September 2023, with a wind-down to May 2024. These are FINRA's allegations against the two officers, not findings about the bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-2a5c18bf7741df64a37e9513","record":{"id":"display-claim-2a5c18bf7741df64a37e9513","kind":"analysis","text":"According to FINRA's complaint, the two sets of ledgers differed substantially from about 2022, with Synapse's showing more end-user money at the bank than the bank said it held. Press reports cited by four senators say Evolve told Synapse in August 2022 that it intended to end the relationship, and a fintech industry newsletter reported a 2022 e-mail by the bank's Open Banking controller saying balances tended 'to differ a couple hundred million on the daily'; that e-mail was not retained, and both accounts come from press reports and e-mails disclosed in litigation. The CFPB's complaint against Synapse, to which Evolve is not a party, states that by September 2023 at the latest both companies knew of a deficit of tens of millions of dollars in the funds Evolve held for end users and publicly blamed each other; the deficit's cause remains disputed. Synapse filed for bankruptcy in April 2024, and the dispute was still unresolved when the CFPB sued Synapse in August 2025.","source_ids":["src-027","src-031","src-103","src-029"],"entity_ids":["evolve","synapse","finra","cfpb"],"premise_claim_ids":["c-syn-ledger-gap","c-syn-2022-warnings","c-syn-deficit-known"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to FINRA's complaint, the two sets of ledgers differed substantially from about 2022, with Synapse's showing more end-user money at the bank than the bank said it held. Press reports cited by four senators say Evolve told Synapse in August 2022 that it intended to end the relationship, and a fintech industry newsletter reported a 2022 e-mail by the bank's Open Banking controller saying balances tended 'to differ a couple hundred million on the daily'; that e-mail was not retained, and both accounts come from press reports and e-mails disclosed in litigation. The CFPB's complaint against Synapse, to which Evolve is not a party, states that by September 2023 at the latest both companies knew of a deficit of tens of millions of dollars in the funds Evolve held for end users and publicly blamed each other; the deficit's cause remains disputed. Synapse filed for bankruptcy in April 2024, and the dispute was still unresolved when the CFPB sued Synapse in August 2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-59a97af5859997cbb722f266","record":{"id":"display-claim-59a97af5859997cbb722f266","kind":"analysis","text":"A business magazine, citing bankruptcy-court records, reported that in September 2023 Synapse told Evolve an internal review had found discrepancies of about $13 million and alleged that the bank had paid itself fees from customer funds, some of which it was not entitled to. On September 25, 2023 Evolve notified Synapse that it was in breach of contract and withheld monthly payments of more than $40 million; two days later Pathak accused the bank of 'persistent negligence' and 'misappropriation of consumer funds', while acknowledging that Synapse may have 'incorrectly received' $3.25 million. An Evolve spokesperson said any accounting errors were Synapse's responsibility and that the bank had given Synapse detailed information on every fee, which Synapse as programme manager was to allocate. According to a business magazine, Synapse committed to pay a little over half of the $3.25 million and Evolve agreed in October to cover the rest. An online encyclopedia, citing a business magazine, says Synapse's board considered replacing Pathak in 2023 over ledger complaints, a secondary account of board deliberations for which no board record was retained.","source_ids":["src-096","src-075"],"entity_ids":["evolve","synapse","sankaet-pathak"],"premise_claim_ids":["c-syn-sept-2023","c-syn-board-pathak"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A business magazine, citing bankruptcy-court records, reported that in September 2023 Synapse told Evolve an internal review had found discrepancies of about $13 million and alleged that the bank had paid itself fees from customer funds, some of which it was not entitled to. On September 25, 2023 Evolve notified Synapse that it was in breach of contract and withheld monthly payments of more than $40 million; two days later Pathak accused the bank of 'persistent negligence' and 'misappropriation of consumer funds', while acknowledging that Synapse may have 'incorrectly received' $3.25 million. An Evolve spokesperson said any accounting errors were Synapse's responsibility and that the bank had given Synapse detailed information on every fee, which Synapse as programme manager was to allocate. According to a business magazine, Synapse committed to pay a little over half of the $3.25 million and Evolve agreed in October to cover the rest. An online encyclopedia, citing a business magazine, says Synapse's board considered replacing Pathak in 2023 over ledger complaints, a secondary account of board deliberations for which no board record was retained."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-53b9527f87e45db2ec19fa6f","record":{"id":"display-claim-53b9527f87e45db2ec19fa6f","kind":"analysis","text":"The same September, according to a business magazine's account, Synapse learned that Mercury, then about 35% of its business by Pathak's account, would move more than $3 billion of deposits to work directly with Evolve; FINRA describes Synapse's biggest customer, with about $3 billion at the bank, partnering directly with it around October 2023, and Synapse contending that the bank migrated about $49 million more than it was entitled to. When Synapse stopped operating in May 2024, its records showed about $92 million more in end-user deposits at the bank than the bank said it held.","source_ids":["src-096","src-027"],"entity_ids":["evolve","synapse","mercury","sankaet-pathak","finra"],"premise_claim_ids":["c-syn-mercury-move","c-syn-ledger-gap"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The same September, according to a business magazine's account, Synapse learned that Mercury, then about 35% of its business by Pathak's account, would move more than $3 billion of deposits to work directly with Evolve; FINRA describes Synapse's biggest customer, with about $3 billion at the bank, partnering directly with it around October 2023, and Synapse contending that the bank migrated about $49 million more than it was entitled to. When Synapse stopped operating in May 2024, its records showed about $92 million more in end-user deposits at the bank than the bank said it held."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-72ce0b8ea27ae1b338208457","record":{"id":"display-claim-72ce0b8ea27ae1b338208457","kind":"analysis","text":"Synapse Brokerage LLC, a FINRA member since 2006 that Synapse acquired in July 2020, launched a cash-management programme in September 2023 as part of Synapse's move away from the bank. Customers' money went first to a deposit bank and was then to be swept to other programme banks, while Synapse kept the ledger. FINRA alleges that after a large fintech notified its users on October 5, 2023, about $200 million of some 650,000 users moved from the bank to the programme in eight days; California's regulator says Yotta agreed to move its savings accounts to Synapse Brokerage around October 11, 2023, while its customers kept Evolve routing and account numbers. The CFPB alleges in its complaint against Synapse that Evolve was not one of the banks holding brokerage deposits but kept sponsoring debit cards and receiving direct deposits for users who moved.","source_ids":["src-027","src-052","src-026","src-029"],"entity_ids":["synapse-brokerage","synapse","evolve","finra","yotta","dfpi","cfpb"],"premise_claim_ids":["c-syn-brokerage-program","c-syn-migration","c-syn-evolve-role-after"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Synapse Brokerage LLC, a FINRA member since 2006 that Synapse acquired in July 2020, launched a cash-management programme in September 2023 as part of Synapse's move away from the bank. Customers' money went first to a deposit bank and was then to be swept to other programme banks, while Synapse kept the ledger. FINRA alleges that after a large fintech notified its users on October 5, 2023, about $200 million of some 650,000 users moved from the bank to the programme in eight days; California's regulator says Yotta agreed to move its savings accounts to Synapse Brokerage around October 11, 2023, while its customers kept Evolve routing and account numbers. The CFPB alleges in its complaint against Synapse that Evolve was not one of the banks holding brokerage deposits but kept sponsoring debit cards and receiving direct deposits for users who moved."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a168db8deecd0e2172e83379","record":{"id":"display-claim-a168db8deecd0e2172e83379","kind":"analysis","text":"FINRA further alleges that around December 31, 2023 the bank stopped sweeping brokerage customers' incoming funds into the programme and held them in omnibus accounts in Synapse's name, without telling customers, and that Synapse then 'reallocated' funds between the bank and the programme banks by changing ledger entries without moving money, including $85 million of one fintech's funds, according to a fintech newsletter's reading of the complaint.","source_ids":["src-027","src-026"],"entity_ids":["evolve","synapse","synapse-brokerage","finra"],"premise_claim_ids":["c-syn-dec-2023"],"qualification":"","response":"","outcome":""},"reading":"Analysis: FINRA further alleges that around December 31, 2023 the bank stopped sweeping brokerage customers' incoming funds into the programme and held them in omnibus accounts in Synapse's name, without telling customers, and that Synapse then 'reallocated' funds between the bank and the programme banks by changing ledger entries without moving money, including $85 million of one fintech's funds, according to a fintech newsletter's reading of the complaint."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-762fa5895727503cc92dfedd","record":{"id":"display-claim-762fa5895727503cc92dfedd","kind":"analysis","text":"Synapse filed for Chapter 11 on April 22, 2024 and sought approval of a sale; the CFPB's complaint says the buyer required Synapse and Evolve to settle their dispute and ensure that balances at Evolve were fully funded, which they could not do. On May 11, 2024, according to the CFPB, Synapse cut off the bank's access to the dashboard of end users' balances and stopped the daily ledger reports, and Evolve stopped processing transactions and froze all activity for every end user. FINRA says funds at the programme banks were returned in May and June 2024 while those at the bank remained inaccessible; the bank began releasing funds in November 2024, and customers whose funds were allocated to it recovered only a fraction. These are allegations in the CFPB and FINRA complaints; an online encyclopedia describes the freeze as lasting five months and locking tens of thousands of customers out of their accounts.","source_ids":["src-029","src-027","src-004"],"entity_ids":["synapse","evolve","cfpb","synapse-brokerage","finra"],"premise_claim_ids":["c-syn-bankruptcy","c-syn-freeze"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Synapse filed for Chapter 11 on April 22, 2024 and sought approval of a sale; the CFPB's complaint says the buyer required Synapse and Evolve to settle their dispute and ensure that balances at Evolve were fully funded, which they could not do. On May 11, 2024, according to the CFPB, Synapse cut off the bank's access to the dashboard of end users' balances and stopped the daily ledger reports, and Evolve stopped processing transactions and froze all activity for every end user. FINRA says funds at the programme banks were returned in May and June 2024 while those at the bank remained inaccessible; the bank began releasing funds in November 2024, and customers whose funds were allocated to it recovered only a fraction. These are allegations in the CFPB and FINRA complaints; an online encyclopedia describes the freeze as lasting five months and locking tens of thousands of customers out of their accounts."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ba06e4a93b4a3d41c3692618","record":{"id":"display-claim-ba06e4a93b4a3d41c3692618","kind":"analysis","text":"The dispute did not end with the bankruptcy. An online encyclopedia records that in September 2024 Synapse accused Evolve of misappropriating customer funds, an accusation no court has ruled on; Evolve told the bankruptcy court its reconciliation showed Synapse's ledgers were wrong and rejected the former chief executive's claim that the missing funds are at Evolve.","source_ids":["src-004","src-030"],"entity_ids":["synapse","evolve"],"premise_claim_ids":["c-syn-misappropriation-claim"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The dispute did not end with the bankruptcy. An online encyclopedia records that in September 2024 Synapse accused Evolve of misappropriating customer funds, an accusation no court has ruled on; Evolve told the bankruptcy court its reconciliation showed Synapse's ledgers were wrong and rejected the former chief executive's claim that the missing funds are at Evolve."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-22032d62d7e53966ef8c0ee1","record":{"id":"display-claim-22032d62d7e53966ef8c0ee1","kind":"analysis","text":"Evolve engaged Ankura Consulting Group to reconcile the funds it held for Synapse Brokerage end users, using its own records, Federal Reserve data and information from the Chapter 11 trustee. In an update filed with the trustee's report of November 12, 2024, it said the reconciliation was completed on October 18, 2024; that on November 4 it e-mailed about 118,000 end users a link to a reconciliation website showing each user's reconstructed 'Synapse ecosystem balance' and 'Evolve payment' as of May 17, 2024; and that fewer than 4.3% had appealed by November 11. Evolve said Ankura's work showed Synapse's ledgers to be contradicted by Synapse's own transaction data, Federal Reserve data and the bank's records, that other partner banks had not joined, and that Ankura therefore could not say where funds were outside Evolve; it offered to share its transaction data with the other banks.","source_ids":["src-029","src-030"],"entity_ids":["evolve","ankura","synapse-brokerage","synapse"],"premise_claim_ids":["c-rec-ankura","c-rec-limits"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve engaged Ankura Consulting Group to reconcile the funds it held for Synapse Brokerage end users, using its own records, Federal Reserve data and information from the Chapter 11 trustee. In an update filed with the trustee's report of November 12, 2024, it said the reconciliation was completed on October 18, 2024; that on November 4 it e-mailed about 118,000 end users a link to a reconciliation website showing each user's reconstructed 'Synapse ecosystem balance' and 'Evolve payment' as of May 17, 2024; and that fewer than 4.3% had appealed by November 11. Evolve said Ankura's work showed Synapse's ledgers to be contradicted by Synapse's own transaction data, Federal Reserve data and the bank's records, that other partner banks had not joined, and that Ankura therefore could not say where funds were outside Evolve; it offered to share its transaction data with the other banks."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-6b9e38f488b0387dfe219681","record":{"id":"display-claim-6b9e38f488b0387dfe219681","kind":"analysis","text":"On October 23, 2024 the bank announced that Rust Consulting would administer the payments. Founder Scot Lenoir said the bank had sorted through more than 100 million transaction records to evaluate 'the flawed ledgers from Synapse'. a fintech industry newsletter reported in February 2025, citing unnamed sources, that chief financial officer Mark Mosteller had overseen Ankura's work, which 'purported to show many Synapse end users were entitled to pennies on the dollar, or nothing at all, from Evolve'.","source_ids":["src-038","src-008","src-011"],"entity_ids":["evolve","rust-consulting","scot-lenoir","synapse-brokerage","ankura","mark-mosteller"],"premise_claim_ids":["c-rec-rust","c-rec-pennies"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On October 23, 2024 the bank announced that Rust Consulting would administer the payments. Founder Scot Lenoir said the bank had sorted through more than 100 million transaction records to evaluate 'the flawed ledgers from Synapse'. a fintech industry newsletter reported in February 2025, citing unnamed sources, that chief financial officer Mark Mosteller had overseen Ankura's work, which 'purported to show many Synapse end users were entitled to pennies on the dollar, or nothing at all, from Evolve'."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ada8a0f7408ef89f9e31a095","record":{"id":"display-claim-ada8a0f7408ef89f9e31a095","kind":"analysis","text":"The trustee's twelfth status report shows Evolve holding $46,926,558 of Synapse end users' for-benefit-of funds on May 24, 2024, of which $21,000,000 (44%) had been distributed by November 12, 2024, against 99% at AMG National Trust; across the four banks, $187.1 million of $219.0 million (85%) had been paid out. Evolve also reported paying $5.66 million of demand-deposit funds to 42,031 users of eight platforms. Users who had chosen how to receive the FBO funds from Evolve came from Juno, YieldStreet, Yotta and Clerkie.","source_ids":["src-030"],"entity_ids":["evolve","amg-national-trust","lineage-bank","american-bank","synapse","juno","yieldstreet","yotta","clerkie"],"premise_claim_ids":["c-rec-trustee-fbo","c-rec-platforms"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The trustee's twelfth status report shows Evolve holding $46,926,558 of Synapse end users' for-benefit-of funds on May 24, 2024, of which $21,000,000 (44%) had been distributed by November 12, 2024, against 99% at AMG National Trust; across the four banks, $187.1 million of $219.0 million (85%) had been paid out. Evolve also reported paying $5.66 million of demand-deposit funds to 42,031 users of eight platforms. Users who had chosen how to receive the FBO funds from Evolve came from Juno, YieldStreet, Yotta and Clerkie."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-50833d3fe5e7c43ad1942f46","record":{"id":"display-claim-50833d3fe5e7c43ad1942f46","kind":"analysis","text":"The trustee said Evolve, citing pending litigation, had declined to give her most details of its reconciliation, so she knew less about its expected distributions than end users did; she was disappointed in the results so far while recognising its substantial distributions. She kept her estimate of the shortfall across Synapse's partner banks at $65 million to $95 million; the CFPB's complaint gives her estimate as $60 million to $90 million. Neither estimate attributes the shortfall to a particular bank.","source_ids":["src-030","src-029"],"entity_ids":["evolve","synapse","cfpb"],"premise_claim_ids":["c-rec-trustee-view","c-rec-shortfall"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The trustee said Evolve, citing pending litigation, had declined to give her most details of its reconciliation, so she knew less about its expected distributions than end users did; she was disappointed in the results so far while recognising its substantial distributions. She kept her estimate of the shortfall across Synapse's partner banks at $65 million to $95 million; the CFPB's complaint gives her estimate as $60 million to $90 million. Neither estimate attributes the shortfall to a particular bank."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a9df20d5afb046623cc95961","record":{"id":"display-claim-a9df20d5afb046623cc95961","kind":"analysis","text":"In their section of the trustee's report, AMG National Trust and Lineage Bank said that, by their summary of Synapse-related transfers, about $957.6 million more had flowed into Evolve from them than out, gross totals that do not by themselves show what any bank owed users at the freeze. They called Evolve's suggestion that they might still hold substantial funds 'irresponsible and disingenuous' and cited Yotta users told to expect $579.00 from Evolve against a reconstructed balance of $282,100. Evolve's position is that its reconciliation showed Synapse's ledgers were wrong and that the other banks should share transaction data. A banking trade publication reported in April 2025 that the two banks had called an accurate reconciliation 'impossible' because of Synapse's bulk transfers, and that Lineage said it had returned about 99% of the funds it held.","source_ids":["src-030","src-110"],"entity_ids":["amg-national-trust","lineage-bank","evolve","yotta","synapse"],"premise_claim_ids":["c-rec-amg-lineage","c-rec-later-dispute"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In their section of the trustee's report, AMG National Trust and Lineage Bank said that, by their summary of Synapse-related transfers, about $957.6 million more had flowed into Evolve from them than out, gross totals that do not by themselves show what any bank owed users at the freeze. They called Evolve's suggestion that they might still hold substantial funds 'irresponsible and disingenuous' and cited Yotta users told to expect $579.00 from Evolve against a reconstructed balance of $282,100. Evolve's position is that its reconciliation showed Synapse's ledgers were wrong and that the other banks should share transaction data. A banking trade publication reported in April 2025 that the two banks had called an accurate reconciliation 'impossible' because of Synapse's bulk transfers, and that Lineage said it had returned about 99% of the funds it held."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-1fb50861b1f5e45defd54686","record":{"id":"display-claim-1fb50861b1f5e45defd54686","kind":"analysis","text":"In a November 2024 open letter, according to a banking trade publication, Evolve said users had received, or chosen how to receive, more than $24.5 million, and told many of them that it held less than Synapse's ledger showed and that the missing funds were with other banks; AMG and Lineage denied holding substantial additional user funds. Senators cited cases from the press: a customer with about $130,000 in a fintech account told in November 2024 that Evolve held $1,182 in her name, and a Yotta customer with nearly $50,000 who recovered $1.49.","source_ids":["src-104","src-031"],"entity_ids":["evolve","amg-national-trust","lineage-bank","yotta"],"premise_claim_ids":["c-rec-open-letter","c-rec-payouts-examples"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In a November 2024 open letter, according to a banking trade publication, Evolve said users had received, or chosen how to receive, more than $24.5 million, and told many of them that it held less than Synapse's ledger showed and that the missing funds were with other banks; AMG and Lineage denied holding substantial additional user funds. Senators cited cases from the press: a customer with about $130,000 in a fintech account told in November 2024 that Evolve held $1,182 in her name, and a Yotta customer with nearly $50,000 who recovered $1.49."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-17722d60cb06548319dfa430","record":{"id":"display-claim-17722d60cb06548319dfa430","kind":"analysis","text":"The CFPB states that AMG began distributing funds in May 2024 and Evolve and Lineage in June 2024, and that in March 2025 the banks were still paying, mostly very small balances without valid addresses and returned payments. On January 8, 2026, some 607 days after the freeze, Evolve posted that Ankura's continued review had found more users migrated to Synapse Brokerage than previously disclosed and other ledger irregularities, and that it would pay certain users in the coming days; it did not disclose the amount, and a representative did not answer the newsletter's questions.","source_ids":["src-029","src-103"],"entity_ids":["evolve","amg-national-trust","lineage-bank","cfpb","ankura","synapse-brokerage"],"premise_claim_ids":["c-rec-distributions","c-rec-2026-statement"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The CFPB states that AMG began distributing funds in May 2024 and Evolve and Lineage in June 2024, and that in March 2025 the banks were still paying, mostly very small balances without valid addresses and returned payments. On January 8, 2026, some 607 days after the freeze, Evolve posted that Ankura's continued review had found more users migrated to Synapse Brokerage than previously disclosed and other ledger irregularities, and that it would pay certain users in the coming days; it did not disclose the amount, and a representative did not answer the newsletter's questions."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-30ac6da9b834d2c62cf8c535","record":{"id":"display-claim-30ac6da9b834d2c62cf8c535","kind":"analysis","text":"The CFPB sued Synapse in its bankruptcy case in August 2025; the stipulated judgment of September 12, 2025 includes a ban on selling customer information and a $1 civil money penalty that lets the Bureau use its Civil Penalty Fund for harmed consumers. On November 28, 2025 it allocated $46,248,291 from the fund to eligible victims of the Synapse bankruptcy; California's regulator said in May 2026 that Yotta customers with a positive balance on May 17, 2024 might claim compensation but that the claims process had not begun. A Stifel analyst, according to a fintech industry newsletter, speculated that the allocation might reduce any net liability Evolve faces.","source_ids":["src-036","src-029","src-037","src-035"],"entity_ids":["cfpb","synapse","dfpi","yotta","evolve"],"premise_claim_ids":["c-rec-cfpb-judgment","c-rec-cfpb-fund"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The CFPB sued Synapse in its bankruptcy case in August 2025; the stipulated judgment of September 12, 2025 includes a ban on selling customer information and a $1 civil money penalty that lets the Bureau use its Civil Penalty Fund for harmed consumers. On November 28, 2025 it allocated $46,248,291 from the fund to eligible victims of the Synapse bankruptcy; California's regulator said in May 2026 that Yotta customers with a positive balance on May 17, 2024 might claim compensation but that the claims process had not begun. A Stifel analyst, according to a fintech industry newsletter, speculated that the allocation might reduce any net liability Evolve faces."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-47dd6ad5f300176fff78858e","record":{"id":"display-claim-47dd6ad5f300176fff78858e","kind":"analysis","text":"On September 13, 2024 Yotta Technologies, a fintech whose customers' accounts were held at Evolve through Synapse, sued Evolve Bancorp and Evolve Bank & Trust in the Northern District of California (No. 3:24-cv-06456); the holding company was dismissed by stipulation in January 2025. Its amended complaint alleges fraud. A discovery order of January 22, 2026 lists among the alleged misrepresentations the balances Evolve reported to Yotta through Synapse from 2020 to May 2024, an e-mail of about September 25, 2023 from Evolve president Hank Word to Yotta co-founder Adam Moelis calling the Synapse problems 'some contractual issues' being handled to 'protect end users', and an October 2023 e-mail from Scot Lenoir saying Yotta could 'transition to another bank'. Evolve filed a sealed declaration by Word in support of its motion to dismiss.","source_ids":["src-087","src-069","src-088","src-110"],"entity_ids":["yotta","evolve","evolve-bancorp","hank-word","scot-lenoir","adam-moelis"],"premise_claim_ids":["c-lit-yotta-filed","c-lit-yotta-claims","c-lit-word-declaration"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On September 13, 2024 Yotta Technologies, a fintech whose customers' accounts were held at Evolve through Synapse, sued Evolve Bancorp and Evolve Bank & Trust in the Northern District of California (No. 3:24-cv-06456); the holding company was dismissed by stipulation in January 2025. Its amended complaint alleges fraud. A discovery order of January 22, 2026 lists among the alleged misrepresentations the balances Evolve reported to Yotta through Synapse from 2020 to May 2024, an e-mail of about September 25, 2023 from Evolve president Hank Word to Yotta co-founder Adam Moelis calling the Synapse problems 'some contractual issues' being handled to 'protect end users', and an October 2023 e-mail from Scot Lenoir saying Yotta could 'transition to another bank'. Evolve filed a sealed declaration by Word in support of its motion to dismiss."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-eeb0a0750ec69576f11b3a6e","record":{"id":"display-claim-eeb0a0750ec69576f11b3a6e","kind":"analysis","text":"In the same order the magistrate judge refused to compel documents withheld as confidential supervisory information but gave Yotta three more hours with Evolve's corporate designee, finding that Evolve's counsel's 'many speaking objections and efforts to coach the witness disrupted the deposition'. According to Yotta's part of a joint discovery letter, as reported by a fintech industry newsletter, former chief technology officer W. Christopher Staab testified that the gap between the bank's funds and Synapse's ledgers likely led Evolve to fail to obtain the deposit insurance it needed, and Word invoked the Fifth Amendment when asked whether Yotta users' funds were FDIC-insured, which is not itself evidence of wrongdoing. Evolve cited its privacy obligations under the Gramm-Leach-Bliley Act for refusing to turn over documents containing end users' personal information; Word did not respond to the newsletter's request for comment.","source_ids":["src-069","src-103"],"entity_ids":["evolve","yotta","christopher-staab","hank-word","ankura"],"premise_claim_ids":["c-lit-yotta-discovery","c-lit-yotta-testimony"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In the same order the magistrate judge refused to compel documents withheld as confidential supervisory information but gave Yotta three more hours with Evolve's corporate designee, finding that Evolve's counsel's 'many speaking objections and efforts to coach the witness disrupted the deposition'. According to Yotta's part of a joint discovery letter, as reported by a fintech industry newsletter, former chief technology officer W. Christopher Staab testified that the gap between the bank's funds and Synapse's ledgers likely led Evolve to fail to obtain the deposit insurance it needed, and Word invoked the Fifth Amendment when asked whether Yotta users' funds were FDIC-insured, which is not itself evidence of wrongdoing. Evolve cited its privacy obligations under the Gramm-Leach-Bliley Act for refusing to turn over documents containing end users' personal information; Word did not respond to the newsletter's request for comment."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-deaf4e8b467ba56d095d58df","record":{"id":"display-claim-deaf4e8b467ba56d095d58df","kind":"analysis","text":"Evolve argued, according to a banking trade publication, that the complaint fell short on allegations against it and was more about Synapse. On February 18, 2026 the court granted Evolve's motion to dismiss the amended complaint and closed the case; Yotta appealed to the Ninth Circuit (No. 26-1535) on March 11, 2026, and an appellate mandate was entered on the district docket on October 6, 2026, its content not shown in the retained docket.","source_ids":["src-069","src-088","src-110"],"entity_ids":["yotta","evolve","hank-word","scot-lenoir","adam-moelis"],"premise_claim_ids":["c-lit-yotta-claims"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Evolve argued, according to a banking trade publication, that the complaint fell short on allegations against it and was more about Synapse. On February 18, 2026 the court granted Evolve's motion to dismiss the amended complaint and closed the case; Yotta appealed to the Ninth Circuit (No. 26-1535) on March 11, 2026, and an appellate mandate was entered on the district docket on October 6, 2026, its content not shown in the retained docket."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-272f0d96876ddd5420dd4eb9","record":{"id":"display-claim-272f0d96876ddd5420dd4eb9","kind":"analysis","text":"In November 2024 end users of Synapse-linked fintechs, mainly Yotta and Juno customers, filed a proposed class action in Colorado against American Bank, AMG National Trust, Lineage Bank, Evolve Bank & Trust and Evolve Bancorp. According to a banking trade publication's account, the complaint alleges that about $85 million of about 100,000 customers could not be traced because of ledger irregularities and that the banks kept no copy of the ledger; the plaintiffs told the court that tracing hundreds of millions of dollars through pooled accounts involves more than ten terabytes of data and that no one has completed a full reconciliation; these are allegations and representations, not findings. AMG has moved for summary judgment, saying it paid out all or almost all funds on Synapse Brokerage's instructions and the final trial balance, owed the plaintiffs no duty and holds none of their money; the plaintiffs dispute its data and method. In the consolidated case (No. 24-cv-03259), which since October 2025 also includes a California case transferred there, fact and class discovery closes on January 15, 2027 and the class-certification motion is due on March 17, 2027.","source_ids":["src-104","src-113","src-109"],"entity_ids":["evolve","evolve-bancorp","amg-national-trust","lineage-bank","american-bank","synapse"],"premise_claim_ids":["c-lit-colorado","c-lit-colorado-claims"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In November 2024 end users of Synapse-linked fintechs, mainly Yotta and Juno customers, filed a proposed class action in Colorado against American Bank, AMG National Trust, Lineage Bank, Evolve Bank & Trust and Evolve Bancorp. According to a banking trade publication's account, the complaint alleges that about $85 million of about 100,000 customers could not be traced because of ledger irregularities and that the banks kept no copy of the ledger; the plaintiffs told the court that tracing hundreds of millions of dollars through pooled accounts involves more than ten terabytes of data and that no one has completed a full reconciliation; these are allegations and representations, not findings. AMG has moved for summary judgment, saying it paid out all or almost all funds on Synapse Brokerage's instructions and the final trial balance, owed the plaintiffs no duty and holds none of their money; the plaintiffs dispute its data and method. In the consolidated case (No. 24-cv-03259), which since October 2025 also includes a California case transferred there, fact and class discovery closes on January 15, 2027 and the class-certification motion is due on March 17, 2027."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-37b121c160d5d758763f2f92","record":{"id":"display-claim-37b121c160d5d758763f2f92","kind":"analysis","text":"A separate proposed class action filed on November 27, 2024 in the Central District of California against Lineage, American Bank, AMG, Evolve Bancorp and the bank was transferred to Colorado on October 16, 2025 under the first-to-file rule, leaving the plaintiff's request to add Synapse, Synapse Brokerage, Mark Paverman and Jeffrey Stanley as defendants to that court. On April 4, 2025 a Yotta customer sued Evolve Bank & Trust, Evolve Bancorp and Lineage Bank in the Western District of Tennessee, alleging negligent oversight and mishandling of funds; his account had shown $4,420.50 and he received $3.46. Evolve declined to comment on the active litigation.","source_ids":["src-109","src-110"],"entity_ids":["evolve","evolve-bancorp","lineage-bank","american-bank","amg-national-trust","yotta"],"premise_claim_ids":["c-lit-california","c-lit-tennessee"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A separate proposed class action filed on November 27, 2024 in the Central District of California against Lineage, American Bank, AMG, Evolve Bancorp and the bank was transferred to Colorado on October 16, 2025 under the first-to-file rule, leaving the plaintiff's request to add Synapse, Synapse Brokerage, Mark Paverman and Jeffrey Stanley as defendants to that court. On April 4, 2025 a Yotta customer sued Evolve Bank & Trust, Evolve Bancorp and Lineage Bank in the Western District of Tennessee, alleging negligent oversight and mishandling of funds; his account had shown $4,420.50 and he received $3.46. Evolve declined to comment on the active litigation."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-f23e44412d7ce00469af495b","record":{"id":"display-claim-f23e44412d7ce00469af495b","kind":"analysis","text":"On August 28, 2025 FINRA's Department of Enforcement charged two former Synapse Brokerage officers: Jeffrey Alan Stanley, over supervision of the cash-management programme and transfers of customer funds without adequate authorisation, and Mark Elliot Paverman, over record-keeping. Paverman settled in January 2026 without admitting or denying the allegations, with a $20,000 fine and a 12-month suspension from principal roles; Stanley settled in May 2026, accepting suspensions of four months in all capacities and 12 months as a principal with no fine because of his financial status.","source_ids":["src-027","src-068","src-032","src-078"],"entity_ids":["finra","jeffrey-stanley","mark-paverman","synapse-brokerage"],"premise_claim_ids":["c-lit-finra-complaint","c-lit-finra-paverman","c-lit-finra-stanley"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On August 28, 2025 FINRA's Department of Enforcement charged two former Synapse Brokerage officers: Jeffrey Alan Stanley, over supervision of the cash-management programme and transfers of customer funds without adequate authorisation, and Mark Elliot Paverman, over record-keeping. Paverman settled in January 2026 without admitting or denying the allegations, with a $20,000 fine and a 12-month suspension from principal roles; Stanley settled in May 2026, accepting suspensions of four months in all capacities and 12 months as a principal with no fine because of his financial status."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a126445160abebe890c74e88","record":{"id":"display-claim-a126445160abebe890c74e88","kind":"analysis","text":"A business magazine reported in March 2025 that a court filing had revealed a grand jury convened by the U.S. Attorney's Office for the Southern District of New York in a criminal investigation into Synapse, and that prosecutors had asked about the shortfall and Synapse's relationship with Evolve; Pathak said prosecutors had not contacted him, and no charges appear in the retained record. On May 15, 2026 California's financial regulator entered a consent order with Yotta, finding that it had advertised savings as FDIC-insured 'through our partner bank Evolve Bank & Trust' and that at least 18,155 California customers lost access to at least $28 million after the bankruptcy; Yotta agreed to a $1,000,000 penalty. Evolve is not a party to the order.","source_ids":["src-096","src-037","src-052"],"entity_ids":["synapse","evolve","sankaet-pathak","dfpi","yotta","adam-moelis"],"premise_claim_ids":["c-lit-grand-jury","c-lit-dfpi-yotta"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A business magazine reported in March 2025 that a court filing had revealed a grand jury convened by the U.S. Attorney's Office for the Southern District of New York in a criminal investigation into Synapse, and that prosecutors had asked about the shortfall and Synapse's relationship with Evolve; Pathak said prosecutors had not contacted him, and no charges appear in the retained record. On May 15, 2026 California's financial regulator entered a consent order with Yotta, finding that it had advertised savings as FDIC-insured 'through our partner bank Evolve Bank & Trust' and that at least 18,155 California customers lost access to at least $28 million after the bankruptcy; Yotta agreed to a $1,000,000 penalty. Evolve is not a party to the order."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-3f42efa685408b5301d3f5e2","record":{"id":"display-claim-3f42efa685408b5301d3f5e2","kind":"analysis","text":"Effective June 11, 2024, the Board of Governors of the Federal Reserve System and the Arkansas State Bank Department issued a cease-and-desist order upon consent to Evolve Bancorp, Inc. and Evolve Bank & Trust (Docket Nos. 24-012-B-HC and 24-012-B-SM) under section 8 of the Federal Deposit Insurance Act. The companies consented to settle without a formal proceeding, before any notice of charges, hearing or adjudication of facts or law, so the order is not a court judgment. Lenoir signed for the holding company as chairman and Stafford for the bank as president and chief executive. The order remains in effect until the supervisors stay, modify, terminate or suspend it in writing.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp","federal-reserve-board","arkansas-state-bank-department","scot-lenoir","scott-stafford"],"premise_claim_ids":["c-reg-order","c-brd-fed-signatories"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Effective June 11, 2024, the Board of Governors of the Federal Reserve System and the Arkansas State Bank Department issued a cease-and-desist order upon consent to Evolve Bancorp, Inc. and Evolve Bank & Trust (Docket Nos. 24-012-B-HC and 24-012-B-SM) under section 8 of the Federal Deposit Insurance Act. The companies consented to settle without a formal proceeding, before any notice of charges, hearing or adjudication of facts or law, so the order is not a court judgment. Lenoir signed for the holding company as chairman and Stafford for the bank as president and chief executive. The order remains in effect until the supervisors stay, modify, terminate or suspend it in writing."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-d1352810efa25eea2308a1d5","record":{"id":"display-claim-d1352810efa25eea2308a1d5","kind":"analysis","text":"The order recites that the Federal Reserve Bank of St. Louis and the Arkansas department found risk-management deficiencies in the Open Banking Division in a safety-and-soundness examination issued on August 11, 2023; that the Reserve Bank found consumer-compliance risk-management deficiencies in the division in an examination issued on August 30, 2023; and that a further examination issued on January 10, 2024 found additional anti-money-laundering deficiencies amounting to a Bank Secrecy Act compliance-programme violation, together with shortcomings in complying with the sanctions rules of the Treasury's Office of Foreign Assets Control. It also records that the companies had begun remedial action. The order describes the division's strategy as offering deposit accounts and payment processing to fintech partners, which in turn serve end users directly or through other entities.","source_ids":["src-003"],"entity_ids":["evolve","federal-reserve-bank-st-louis","arkansas-state-bank-department"],"premise_claim_ids":["c-reg-order-findings","c-reg-order-baas"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The order recites that the Federal Reserve Bank of St. Louis and the Arkansas department found risk-management deficiencies in the Open Banking Division in a safety-and-soundness examination issued on August 11, 2023; that the Reserve Bank found consumer-compliance risk-management deficiencies in the division in an examination issued on August 30, 2023; and that a further examination issued on January 10, 2024 found additional anti-money-laundering deficiencies amounting to a Bank Secrecy Act compliance-programme violation, together with shortcomings in complying with the sanctions rules of the Treasury's Office of Foreign Assets Control. It also records that the companies had begun remedial action. The order describes the division's strategy as offering deposit accounts and payment processing to fintech partners, which in turn serve end users directly or through other entities."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-fd388a053e86ec1e1126f867","record":{"id":"display-claim-fd388a053e86ec1e1126f867","kind":"analysis","text":"The bank must submit plans acceptable to the supervisors for board oversight; Open Banking risk management, including written board approval before onboarding new fintech partners or products; consumer compliance; liquidity and funding concentrations; interest-rate risk; internal audit; Bank Secrecy Act and anti-money-laundering compliance, customer due diligence, transaction monitoring and suspicious-activity reporting; and sanctions compliance, with quarterly progress reports. It had 30 days to adopt interim monitoring procedures for international wire services, and it must adopt policies that clearly define and maintain the ledger and sub-ledger responsibilities of the bank and its fintech partners, including during a material business disruption. An independent consultant must review fintech partners' transactions through the bank from April 1 to September 30, 2023 to determine whether suspicious activity was properly identified and reported, and any unreported matters found must be reported.","source_ids":["src-003"],"entity_ids":["evolve"],"premise_claim_ids":["c-reg-order-requirements","c-reg-order-transaction-review"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The bank must submit plans acceptable to the supervisors for board oversight; Open Banking risk management, including written board approval before onboarding new fintech partners or products; consumer compliance; liquidity and funding concentrations; interest-rate risk; internal audit; Bank Secrecy Act and anti-money-laundering compliance, customer due diligence, transaction monitoring and suspicious-activity reporting; and sanctions compliance, with quarterly progress reports. It had 30 days to adopt interim monitoring procedures for international wire services, and it must adopt policies that clearly define and maintain the ledger and sub-ledger responsibilities of the bank and its fintech partners, including during a material business disruption. An independent consultant must review fintech partners' transactions through the bank from April 1 to September 30, 2023 to determine whether suspicious activity was properly identified and reported, and any unreported matters found must be reported."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-85ae81a51e11ca257a0c83b2","record":{"id":"display-claim-85ae81a51e11ca257a0c83b2","kind":"analysis","text":"With immediate effect the bank may not, without prior written approval, establish new fintech partners, subsidiaries, business lines, products, programmes, services or programme managers in the Open Banking Division or offer new products to existing partners, and it must analyse the liquidity impact before exiting a fintech relationship. Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest on subordinated debentures, or incur, increase, prepay or guarantee debt without the approval of the Reserve Bank, the Board's Director of Supervision and Regulation and the Arkansas department; the holding company must submit annual cash-flow projections. Both companies must give federal notice before appointing directors or senior executive officers and observe the federal limits on indemnification and severance payments.","source_ids":["src-003"],"entity_ids":["evolve","evolve-bancorp"],"premise_claim_ids":["c-reg-order-limits","c-reg-order-management"],"qualification":"","response":"","outcome":""},"reading":"Analysis: With immediate effect the bank may not, without prior written approval, establish new fintech partners, subsidiaries, business lines, products, programmes, services or programme managers in the Open Banking Division or offer new products to existing partners, and it must analyse the liquidity impact before exiting a fintech relationship. Evolve Bancorp and the bank may not pay dividends, buy back shares or make other capital distributions, including interest on subordinated debentures, or incur, increase, prepay or guarantee debt without the approval of the Reserve Bank, the Board's Director of Supervision and Regulation and the Arkansas department; the holding company must submit annual cash-flow projections. Both companies must give federal notice before appointing directors or senior executive officers and observe the federal limits on indemnification and severance payments."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-8bb61511bf04faa52771053d","record":{"id":"display-claim-8bb61511bf04faa52771053d","kind":"analysis","text":"The Federal Reserve Board's press-release lists for 2025 and 2026, through a release of October 16, 2026, announce terminations of enforcement actions against other banks but none mentioning Evolve Bank & Trust or Evolve Bancorp; that absence is not an official statement of the order's status, and the Board does not necessarily announce every modification.","source_ids":["src-079","src-080"],"entity_ids":["evolve","evolve-bancorp","federal-reserve-board"],"premise_claim_ids":["c-reg-order-in-force"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Federal Reserve Board's press-release lists for 2025 and 2026, through a release of October 16, 2026, announce terminations of enforcement actions against other banks but none mentioning Evolve Bank & Trust or Evolve Bancorp; that absence is not an official statement of the order's status, and the Board does not necessarily announce every modification."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-0b172e916eea92b5ebce5b11","record":{"id":"display-claim-0b172e916eea92b5ebce5b11","kind":"analysis","text":"A fintech industry newsletter reported in July 2024, and again in September 2025, that auditors reviewing the bank's anti-money-laundering practices had found it had not properly screened international wire transfers for about seven years because of a 'coding error' by Hank Word, then its chief technology officer. The audit report is not in the retained record, and no response from the bank or Word to the account was found. The order had required interim monitoring procedures for international wire services within 30 days and an independent consultant's review of the bank's domestic and international wire activity. In September 2025 the newsletter also wrote that the FBI, the U.S. Attorney's Office for the Southern District of New York and the Justice Department's Money Laundering and Asset Recovery Section 'appear to be continuing to probe' Evolve and its partners over as much as $95 million in missing depositor funds and transnational money movement through the bank; it cited no charging document or official statement, and no criminal charge against the bank appears in the retained record.","source_ids":["src-026","src-003"],"entity_ids":["evolve","hank-word"],"premise_claim_ids":["c-reg-coding-error","c-reg-probes"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A fintech industry newsletter reported in July 2024, and again in September 2025, that auditors reviewing the bank's anti-money-laundering practices had found it had not properly screened international wire transfers for about seven years because of a 'coding error' by Hank Word, then its chief technology officer. The audit report is not in the retained record, and no response from the bank or Word to the account was found. The order had required interim monitoring procedures for international wire services within 30 days and an independent consultant's review of the bank's domestic and international wire activity. In September 2025 the newsletter also wrote that the FBI, the U.S. Attorney's Office for the Southern District of New York and the Justice Department's Money Laundering and Asset Recovery Section 'appear to be continuing to probe' Evolve and its partners over as much as $95 million in missing depositor funds and transnational money movement through the bank; it cited no charging document or official statement, and no criminal charge against the bank appears in the retained record."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-4cf25c6471c6ed2594cac9f3","record":{"id":"display-claim-4cf25c6471c6ed2594cac9f3","kind":"analysis","text":"On June 28, 2024 Senators Sherrod Brown, Ron Wyden and Tammy Baldwin, among others, wrote to Evolve's chief executive W. Scott Stafford and to Synapse's equity holders, fintech operators and partner banks that they were collectively responsible for customers' frozen funds, pointed to a potential shortfall of $65 million to $96 million and urged them to restore access immediately. On April 22, 2025 Senators Elizabeth Warren, Baldwin, Wyden and John Fetterman told Federal Reserve Governor Michelle Bowman that the Board had failed to supervise Evolve appropriately, harming more than 100,000 consumers whose funds were frozen, and noted that the bank's 2023 consumer-compliance examination ended in August 2023 while the enforcement action came in June 2024. These letters set out the senators' views and assessments; they are not findings by the Board or a court.","source_ids":["src-060","src-031","src-003"],"entity_ids":["evolve","scott-stafford","synapse","federal-reserve-board"],"premise_claim_ids":["c-reg-senators-2024","c-reg-senators-2025"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On June 28, 2024 Senators Sherrod Brown, Ron Wyden and Tammy Baldwin, among others, wrote to Evolve's chief executive W. Scott Stafford and to Synapse's equity holders, fintech operators and partner banks that they were collectively responsible for customers' frozen funds, pointed to a potential shortfall of $65 million to $96 million and urged them to restore access immediately. On April 22, 2025 Senators Elizabeth Warren, Baldwin, Wyden and John Fetterman told Federal Reserve Governor Michelle Bowman that the Board had failed to supervise Evolve appropriately, harming more than 100,000 consumers whose funds were frozen, and noted that the bank's 2023 consumer-compliance examination ended in August 2023 while the enforcement action came in June 2024. These letters set out the senators' views and assessments; they are not findings by the Board or a court."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a783cda2d81fa0301e8e2a16","record":{"id":"display-claim-a783cda2d81fa0301e8e2a16","kind":"analysis","text":"Citing press reports, the 2025 letter says Evolve told Synapse in August 2022 that it intended to end the relationship, that staff at both companies knew of missing funds by 2023 without notifying customers, that Evolve charged about $26 million in fees directly from Synapse customer accounts between 2019 and 2023, and that reporting suggested a federal grand jury proceeding; the underlying statements are not in the retained record. Evolve's position, as reported elsewhere, is that it gave Synapse detailed information on every fee charged and that allocating fees to platforms and end users was Synapse's responsibility as programme manager.","source_ids":["src-031","src-096"],"entity_ids":["evolve","synapse"],"premise_claim_ids":["c-reg-senators-2025-account"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Citing press reports, the 2025 letter says Evolve told Synapse in August 2022 that it intended to end the relationship, that staff at both companies knew of missing funds by 2023 without notifying customers, that Evolve charged about $26 million in fees directly from Synapse customer accounts between 2019 and 2023, and that reporting suggested a federal grand jury proceeding; the underlying statements are not in the retained record. Evolve's position, as reported elsewhere, is that it gave Synapse detailed information on every fee charged and that allocating fees to platforms and end users was Synapse's responsibility as programme manager."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-fc584583ebfe859d3e03fb23","record":{"id":"display-claim-fc584583ebfe859d3e03fb23","kind":"analysis","text":"On March 23, 2026 Senator Warren, ranking member of the Senate Banking Committee, asked Beast Industries why Step, the teen banking app it was acquiring, which partners with Evolve for banking services, had chosen the bank and whether it knew of Evolve's role in the Synapse fallout, its 2024 data breach and the June 2024 enforcement action. She cited a court mediator's finding that up to $96 million in customer funds could not be located at Evolve or other banks, in part because of poor record-keeping; the mediator's determination itself was not retained.","source_ids":["src-058"],"entity_ids":["evolve","step"],"premise_claim_ids":["c-reg-warren-step"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On March 23, 2026 Senator Warren, ranking member of the Senate Banking Committee, asked Beast Industries why Step, the teen banking app it was acquiring, which partners with Evolve for banking services, had chosen the bank and whether it knew of Evolve's role in the Synapse fallout, its 2024 data breach and the June 2024 enforcement action. She cited a court mediator's finding that up to $96 million in customer funds could not be located at Evolve or other banks, in part because of poor record-keeping; the mediator's determination itself was not retained."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-1b3e5f672ab3992a3266803e","record":{"id":"display-claim-1b3e5f672ab3992a3266803e","kind":"analysis","text":"On January 21, 2016 the federal court for the Western District of Tennessee entered a consent order in United States v. Evolve Bank & Trust (No. 2:16-cv-2040), resolving the Justice Department's claims that the bank discriminated on the basis of disability and of receipt of public assistance by requiring some mortgage applicants to provide a doctor's letter showing that Social Security Disability Insurance and other disability income would continue. The bank agreed to an $86,000 fund for 50 borrowers and to new policies, training and monitoring. Evolve denied the allegations and stated that it had treated applicants fairly and without regard to factors such as disability; the order provided for dismissal with prejudice once the court's retained jurisdiction ended.","source_ids":["src-063"],"entity_ids":["evolve","us-doj"],"premise_claim_ids":["c-enf-doj-2016"],"qualification":"","response":"","outcome":""},"reading":"Analysis: On January 21, 2016 the federal court for the Western District of Tennessee entered a consent order in United States v. Evolve Bank & Trust (No. 2:16-cv-2040), resolving the Justice Department's claims that the bank discriminated on the basis of disability and of receipt of public assistance by requiring some mortgage applicants to provide a doctor's letter showing that Social Security Disability Insurance and other disability income would continue. The bank agreed to an $86,000 fund for 50 borrowers and to new policies, training and monitoring. Evolve denied the allegations and stated that it had treated applicants fairly and without regard to factors such as disability; the order provided for dismissal with prejudice once the court's retained jurisdiction ended."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-dacb988a2e41c774aec3eaa8","record":{"id":"display-claim-dacb988a2e41c774aec3eaa8","kind":"analysis","text":"The Federal Reserve referred the bank to the Justice Department on February 8, 2019 after reviewing mortgages originated in 2014 to 2016. On September 29, 2022 the department sued (No. 2:22-cv-02667), alleging that from at least 2014 through 2019 the bank charged Black, Hispanic and individual female borrowers statistically significantly higher discretionary pricing than comparable white and male borrowers. A consent order of October 17, 2022 required a $1.3 million fund for affected borrowers, a $50,000 civil penalty, revised pricing policies, a fair-lending officer and committee, training and monitoring. The bank denied liability and any wrongdoing, stating that its annual pricing tests for 2014 to 2019 showed no pattern of statistically significant disparities. A fintech industry newsletter reported that the St. Louis Reserve Bank had referred Evolve to the Justice Department three times in ten years over mortgage discrimination, and that the Labor Department's ESOP case below arose from a trust-business deal handled by Kenneth Lenoir; the retained consent orders document two Justice Department cases.","source_ids":["src-062","src-064","src-015"],"entity_ids":["evolve","us-doj","federal-reserve-board","federal-reserve-bank-st-louis","kenneth-lenoir"],"premise_claim_ids":["c-enf-doj-2022","c-enf-referrals"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The Federal Reserve referred the bank to the Justice Department on February 8, 2019 after reviewing mortgages originated in 2014 to 2016. On September 29, 2022 the department sued (No. 2:22-cv-02667), alleging that from at least 2014 through 2019 the bank charged Black, Hispanic and individual female borrowers statistically significantly higher discretionary pricing than comparable white and male borrowers. A consent order of October 17, 2022 required a $1.3 million fund for affected borrowers, a $50,000 civil penalty, revised pricing policies, a fair-lending officer and committee, training and monitoring. The bank denied liability and any wrongdoing, stating that its annual pricing tests for 2014 to 2019 showed no pattern of statistically significant disparities. A fintech industry newsletter reported that the St. Louis Reserve Bank had referred Evolve to the Justice Department three times in ten years over mortgage discrimination, and that the Labor Department's ESOP case below arose from a trust-business deal handled by Kenneth Lenoir; the retained consent orders document two Justice Department cases."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a68c7498df6c53b4ca6a890c","record":{"id":"display-claim-a68c7498df6c53b4ca6a890c","kind":"analysis","text":"In August 2019 the Labor Department announced that the federal court for the Western District of Virginia had ordered Adam Vinoskey, former chief executive of Sentry Equipment Erectors, and Evolve Bank & Trust, the transactional fiduciary of Sentry's employee stock ownership plan, to restore $6,502,500 to the plan. The court found that in December 2010 they approved the plan's purchase of Vinoskey's 51,000 shares at $406 each although the stock had been appraised at $285 in 2009, and that Evolve failed to investigate red flags in the appraisal, breaching its duties of loyalty and prudence. a fintech industry newsletter later reported that the amount was lowered to about $1.9 million on appeal; the appellate decision is not in the retained record.","source_ids":["src-086","src-015"],"entity_ids":["evolve","sentry-equipment","adam-vinoskey","us-dol"],"premise_claim_ids":["c-enf-esop"],"qualification":"","response":"","outcome":""},"reading":"Analysis: In August 2019 the Labor Department announced that the federal court for the Western District of Virginia had ordered Adam Vinoskey, former chief executive of Sentry Equipment Erectors, and Evolve Bank & Trust, the transactional fiduciary of Sentry's employee stock ownership plan, to restore $6,502,500 to the plan. The court found that in December 2010 they approved the plan's purchase of Vinoskey's 51,000 shares at $406 each although the stock had been appraised at $285 in 2009, and that Evolve failed to investigate red flags in the appraisal, breaching its duties of loyalty and prudence. a fintech industry newsletter later reported that the amount was lowered to about $1.9 million on appeal; the appellate decision is not in the retained record."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-a2e1844a32f5bf4af0e6cf45","record":{"id":"display-claim-a2e1844a32f5bf4af0e6cf45","kind":"analysis","text":"Effective June 15, 2022 the Federal Reserve Board assessed a $13,950 civil money penalty on the bank for a pattern or practice of violations of its flood-insurance rules (Docket No. 22-016-CMP-SM), payable to the National Flood Insurance Program; the bank consented without admitting or denying the allegations, and Stafford signed as chief executive. Effective May 26, 2020 the Board issued consent orders of prohibition against Aaron K. Hill and Jessica A. Hill, former employees who ran a mortgage loan production office in Louisville, Kentucky, first for Evolve and then for First Savings Bank. The order states that Aaron Hill concealed the couple's ownership of a lead-management vendor that overcharged both banks and that Jessica Hill was paid by both without reporting to work. The Hills consented without admitting or denying the allegations and before any adjudication; they may not take part in the affairs of an insured institution without approval and must cooperate with the Board's investigations of the banks.","source_ids":["src-059","src-016","src-065","src-066"],"entity_ids":["evolve","federal-reserve-board","scott-stafford","aaron-hill","jessica-hill"],"premise_claim_ids":["c-enf-flood","c-enf-hill"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Effective June 15, 2022 the Federal Reserve Board assessed a $13,950 civil money penalty on the bank for a pattern or practice of violations of its flood-insurance rules (Docket No. 22-016-CMP-SM), payable to the National Flood Insurance Program; the bank consented without admitting or denying the allegations, and Stafford signed as chief executive. Effective May 26, 2020 the Board issued consent orders of prohibition against Aaron K. Hill and Jessica A. Hill, former employees who ran a mortgage loan production office in Louisville, Kentucky, first for Evolve and then for First Savings Bank. The order states that Aaron Hill concealed the couple's ownership of a lead-management vendor that overcharged both banks and that Jessica Hill was paid by both without reporting to work. The Hills consented without admitting or denying the allegations and before any adjudication; they may not take part in the affairs of an insured institution without approval and must cooperate with the Board's investigations of the banks."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-38756bdc6e3edb5bc4a9198d","record":{"id":"display-claim-38756bdc6e3edb5bc4a9198d","kind":"analysis","text":"According to the bank's substitute notice of August 27, 2024, Evolve found in late May 2024 that some systems were not working properly and then established a ransomware attack by the LockBit group, which appears to have gained access when an employee clicked a malicious link. The attackers downloaded customer information from databases and a file share in February and May 2024 and encrypted some data; the bank stopped the attack, saw no new unauthorised activity after May 31, reported to law enforcement and refused to pay, and the stolen data was leaked. It said there was no evidence that customer funds were accessed.","source_ids":["src-044"],"entity_ids":["evolve"],"premise_claim_ids":["c-brc-attack"],"qualification":"","response":"","outcome":""},"reading":"Analysis: According to the bank's substitute notice of August 27, 2024, Evolve found in late May 2024 that some systems were not working properly and then established a ransomware attack by the LockBit group, which appears to have gained access when an employee clicked a malicious link. The attackers downloaded customer information from databases and a file share in February and May 2024 and encrypted some data; the bank stopped the attack, saw no new unauthorised activity after May 31, reported to law enforcement and refused to pay, and the stolen data was leaked. It said there was no evidence that customer funds were accessed."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-f4a84c4a6b8d9cb9c03dd1b6","record":{"id":"display-claim-f4a84c4a6b8d9cb9c03dd1b6","kind":"analysis","text":"The affected data appeared to include names, Social Security numbers, account numbers, dates of birth and contact details of most of its personal, mortgage, trust and small-business customers and of customers of its Open Banking partners, debit card numbers for a small portion, and ACH records with payors' and payees' names and account and routing numbers. Notices began on July 8, 2024 with two years of credit monitoring. Its notice to Maine's attorney general reports a breach on February 9, 2024, discovered on May 29, affecting 7,640,112 people, 20,970 of them in Maine; the retained copy is an archived web copy of the state's listing.","source_ids":["src-044","src-082","src-081"],"entity_ids":["evolve"],"premise_claim_ids":["c-brc-data","c-brc-maine"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The affected data appeared to include names, Social Security numbers, account numbers, dates of birth and contact details of most of its personal, mortgage, trust and small-business customers and of customers of its Open Banking partners, debit card numbers for a small portion, and ACH records with payors' and payees' names and account and routing numbers. Notices began on July 8, 2024 with two years of credit monitoring. Its notice to Maine's attorney general reports a breach on February 9, 2024, discovered on May 29, affecting 7,640,112 people, 20,970 of them in Maine; the retained copy is an archived web copy of the state's listing."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-36b1f42746a553ff978c62f1","record":{"id":"display-claim-36b1f42746a553ff978c62f1","kind":"analysis","text":"Partners reported effects on their own customers: Dave says members' names, Social Security numbers, account numbers, dates of birth and contact details were disclosed, an online encyclopedia records that Affirm, Mercury and Wise told customers they were affected and that Mercury account numbers and balances were exposed, and Affirm cites the incident as an example of third-party risk.","source_ids":["src-041","src-004","src-050","src-042"],"entity_ids":["evolve","dave","affirm","mercury","wise"],"premise_claim_ids":["c-brc-partners"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Partners reported effects on their own customers: Dave says members' names, Social Security numbers, account numbers, dates of birth and contact details were disclosed, an online encyclopedia records that Affirm, Mercury and Wise told customers they were affected and that Mercury account numbers and balances were exposed, and Affirm cites the incident as an example of third-party risk."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-9a65d2b7717c3ce2049f708e","record":{"id":"display-claim-9a65d2b7717c3ce2049f708e","kind":"analysis","text":"After multiple putative class actions against Evolve and fintech partners, the Judicial Panel on Multidistrict Litigation created MDL No. 3127, In re: Evolve Bank & Trust Customer Data Security Breach Litigation, on October 4, 2024, before Chief Judge Sheryl H. Lipman in the Western District of Tennessee; the docket lists Affirm, Branch Messenger, CapitalJ and Yotta Technologies as defendants alongside Evolve. The January 2025 consolidated complaint alleged negligence, breach of third-party-beneficiary contract, unjust enrichment and California statutory claims; these are allegations, and the court made no finding of liability.","source_ids":["src-083","src-084"],"entity_ids":["evolve","affirm","branch","capitalj","yotta"],"premise_claim_ids":["c-brc-mdl"],"qualification":"","response":"","outcome":""},"reading":"Analysis: After multiple putative class actions against Evolve and fintech partners, the Judicial Panel on Multidistrict Litigation created MDL No. 3127, In re: Evolve Bank & Trust Customer Data Security Breach Litigation, on October 4, 2024, before Chief Judge Sheryl H. Lipman in the Western District of Tennessee; the docket lists Affirm, Branch Messenger, CapitalJ and Yotta Technologies as defendants alongside Evolve. The January 2025 consolidated complaint alleged negligence, breach of third-party-beneficiary contract, unjust enrichment and California statutory claims; these are allegations, and the court made no finding of liability."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-2f0c54d7e251899fc4371b51","record":{"id":"display-claim-2f0c54d7e251899fc4371b51","kind":"analysis","text":"After a mediation on January 31, 2025 the parties agreed to settle. The court-approved notice offers class members reimbursement of documented losses up to $3,000 or a flat payment estimated at $20, plus credit monitoring, and says class counsel may seek fees of up to one-third of the fund, stated as $3,789,475.79; the notice's retained text does not state the fund total, which a class-action news site reported as $11.9 million. Evolve denies any wrongdoing, and the notice states that no court has found otherwise. The final hearing was set for November 14, 2025, and on November 13 the court denied an objector's motions to halt final approval; the outcome of the final hearing is not in the retained record.","source_ids":["src-077","src-084","src-115"],"entity_ids":["evolve"],"premise_claim_ids":["c-brc-settlement"],"qualification":"","response":"","outcome":""},"reading":"Analysis: After a mediation on January 31, 2025 the parties agreed to settle. The court-approved notice offers class members reimbursement of documented losses up to $3,000 or a flat payment estimated at $20, plus credit monitoring, and says class counsel may seek fees of up to one-third of the fund, stated as $3,789,475.79; the notice's retained text does not state the fund total, which a class-action news site reported as $11.9 million. Evolve denies any wrongdoing, and the notice states that no court has found otherwise. The final hearing was set for November 14, 2025, and on November 13 the court denied an objector's motions to halt final approval; the outcome of the final hearing is not in the retained record."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-cfa8b7691fb04e5ea38c6c1c","record":{"id":"display-claim-cfa8b7691fb04e5ea38c6c1c","kind":"analysis","text":"FDIC call-report data, which cover the bank alone, show year-end total assets of $451.3 million in 2019, $691.6 million in 2020, $788.1 million in 2021, $1.75 billion in 2022, $1.43 billion in 2023, $1.81 billion in 2024 and $1.29 billion in 2025, with deposits of $373.6 million, $514.8 million, $639.1 million, $1.54 billion, $989.3 million, $1.33 billion and $1.07 billion. Net income was between $4.7 million and $25.5 million a year from 2019 to 2024, peaking in 2022, followed by a net loss of $3.0 million in 2025. Senators described the jump to $1.75 billion as growth after the move to Banking-as-a-Service. The Arkansas regulator gives the bank's total assets as $34.8 million at mid-2006 and $1.46 billion at mid-2025.","source_ids":["src-117","src-118","src-031","src-025","src-024"],"entity_ids":["evolve","fdic"],"premise_claim_ids":["c-fin-fdic-series","c-fin-growth-2019-2022","c-fin-asbd-assets"],"qualification":"","response":"","outcome":""},"reading":"Analysis: FDIC call-report data, which cover the bank alone, show year-end total assets of $451.3 million in 2019, $691.6 million in 2020, $788.1 million in 2021, $1.75 billion in 2022, $1.43 billion in 2023, $1.81 billion in 2024 and $1.29 billion in 2025, with deposits of $373.6 million, $514.8 million, $639.1 million, $1.54 billion, $989.3 million, $1.33 billion and $1.07 billion. Net income was between $4.7 million and $25.5 million a year from 2019 to 2024, peaking in 2022, followed by a net loss of $3.0 million in 2025. Senators described the jump to $1.75 billion as growth after the move to Banking-as-a-Service. The Arkansas regulator gives the bank's total assets as $34.8 million at mid-2006 and $1.46 billion at mid-2025."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-00e083fc21c8313d2f6e77ee","record":{"id":"display-claim-00e083fc21c8313d2f6e77ee","kind":"analysis","text":"The holding company's June 2022 letter reported that in the first quarter of 2022 the Open Banking Division's non-interest income rose 83.8% to $9.3 million, from wire, ACH, card and other payment services, and that it processed 113.2 million transactions against 62.8 million a year earlier.","source_ids":["src-034"],"entity_ids":["evolve-bancorp","evolve","scot-lenoir"],"premise_claim_ids":["c-fin-q1-2022"],"qualification":"","response":"","outcome":""},"reading":"Analysis: The holding company's June 2022 letter reported that in the first quarter of 2022 the Open Banking Division's non-interest income rose 83.8% to $9.3 million, from wire, ACH, card and other payment services, and that it processed 113.2 million transactions against 62.8 million a year earlier."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-d45b89e010bb87993a8cea0b","record":{"id":"display-claim-d45b89e010bb87993a8cea0b","kind":"analysis","text":"At the end of 2025 the FDIC data show uninsured deposits of $411.9 million, equity of $162.4 million and tier 1 capital of $158.3 million; at June 30, 2026 they show total assets of $1.19 billion, deposits of $980.9 million and a year-to-date net loss of $865,000. A regional business publication reported on October 27, 2025 that the bank lost $8.76 million in the first half of 2025 and that chief executive Hartheimer said losses would continue into the next year while it installed guardrails; it described the bank as having five Arkansas branches.","source_ids":["src-117","src-001","src-112"],"entity_ids":["evolve","fdic","robert-hartheimer"],"premise_claim_ids":["c-fin-2025-capital","c-fin-2026-h1","c-fin-h1-2025"],"qualification":"","response":"","outcome":""},"reading":"Analysis: At the end of 2025 the FDIC data show uninsured deposits of $411.9 million, equity of $162.4 million and tier 1 capital of $158.3 million; at June 30, 2026 they show total assets of $1.19 billion, deposits of $980.9 million and a year-to-date net loss of $865,000. A regional business publication reported on October 27, 2025 that the bank lost $8.76 million in the first half of 2025 and that chief executive Hartheimer said losses would continue into the next year while it installed guardrails; it described the bank as having five Arkansas branches."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-ac3e87bca53a6ff67d48389b","record":{"id":"display-claim-ac3e87bca53a6ff67d48389b","kind":"analysis","text":"Reading the fourth-quarter 2025 call report, a fintech industry newsletter reported a year-to-date loss of $14 million at the end of September narrowing to $3 million for the year, helped by lower legal, consulting and advisory fees; deposits on the balance sheet down nearly 20% from a year earlier; deposit and referral fee revenue down 66%; and a leverage ratio of 11.91% and a common equity tier 1 ratio of 17.73%, well capitalised by traditional measures. It also noted a new liability of $26,153,000 described as an 'Open Banking Division Reserve'. The reserve's purpose is not disclosed; the newsletter's list of possibilities, such as further payments to end users or costs of the Synapse matter and civil cases, is speculation, and a bank representative did not respond to its questions.","source_ids":["src-035"],"entity_ids":["evolve"],"premise_claim_ids":["c-fin-2025-trend","c-fin-obd-reserve"],"qualification":"","response":"","outcome":""},"reading":"Analysis: Reading the fourth-quarter 2025 call report, a fintech industry newsletter reported a year-to-date loss of $14 million at the end of September narrowing to $3 million for the year, helped by lower legal, consulting and advisory fees; deposits on the balance sheet down nearly 20% from a year earlier; deposit and referral fee revenue down 66%; and a leverage ratio of 11.91% and a common equity tier 1 ratio of 17.73%, well capitalised by traditional measures. It also noted a new liability of $26,153,000 described as an 'Open Banking Division Reserve'. The reserve's purpose is not disclosed; the newsletter's list of possibilities, such as further payments to end users or costs of the Synapse matter and civil cases, is speculation, and a bank representative did not respond to its questions."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"claims","id":"display-claim-607974229e2c1ab64be49871","record":{"id":"display-claim-607974229e2c1ab64be49871","kind":"analysis","text":"A fintech industry newsletter reported, from audit reports the Federal Reserve released under the Freedom of Information Act, that Crowe audited the bank for 2021, 2022 and 2023 and KPMG for 2024, each giving an unqualified opinion and attesting to internal control over financial reporting, although the bank had been dealing with ledger discrepancies with Synapse of hundreds of millions of dollars since at least November 2022. According to e-mails filed in the bankruptcy, it reported, Crowe asked Synapse in February 2024 to confirm its cash balances at Evolve; Synapse's general counsel noted that the bank's account list included 113 accounts not on the daily data feed and omitted 29 that should have been there, and sought to discuss this with Scot Lenoir and the bank's outside counsel, but Evolve did not respond. The audit reports and e-mails were not retained.","source_ids":["src-047"],"entity_ids":["evolve","crowe","kpmg","synapse","scot-lenoir"],"premise_claim_ids":["c-fin-auditors","c-fin-crowe-confirmation"],"qualification":"","response":"","outcome":""},"reading":"Analysis: A fintech industry newsletter reported, from audit reports the Federal Reserve released under the Freedom of Information Act, that Crowe audited the bank for 2021, 2022 and 2023 and KPMG for 2024, each giving an unqualified opinion and attesting to internal control over financial reporting, although the bank had been dealing with ledger discrepancies with Synapse of hundreds of millions of dollars since at least November 2022. According to e-mails filed in the bankruptcy, it reported, Crowe asked Synapse in February 2024 to confirm its cash balances at Evolve; Synapse's general counsel noted that the bank's account list included 113 accounts not on the daily data feed and omitted 29 that should have been there, and sought to discuss this with Scot Lenoir and the bank's outside counsel, but Evolve did not respond. The audit reports and e-mails were not retained."}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve","record":{"id":"evolve","name":"Evolve Bank & Trust","type":"organization","group":"subject","claim_ids":["c-id-fdic-record","c-id-fed-member","c-id-name-history","c-id-state-charter","c-id-memphis-offices","c-id-mississippi","c-id-lei","c-id-screening","c-grp-fdic-holding","c-grp-2005-purchase","c-grp-2006-structure","c-grp-2015","c-grp-2024","c-grp-2025","c-grp-minor-holder","c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board","c-brd-kit-2024-management","c-brd-kit-2023","c-brd-wharton-2021","c-brd-director-tenures","c-brd-jenkins","c-brd-freeman","c-brd-fed-signatories","c-brd-cro-notice","c-brd-lenoir-steps-down","c-brd-feb-2025-memo","c-brd-stafford-retired","c-brd-hartheimer-appointed","c-brd-word-leaves","c-brd-johnston","c-brd-after-hartheimer","c-brd-no-new-ceo","c-brd-holmes","c-ppl-clanton","c-ppl-bright","c-ppl-mosteller","c-ppl-hartheimer-career","c-fnd-lenoir-other-roles","c-fnd-kenneth","c-reg-order","c-reg-order-findings","c-reg-order-baas","c-reg-order-requirements","c-reg-order-transaction-review","c-reg-order-limits","c-reg-order-management","c-reg-order-in-force","c-reg-coding-error","c-reg-probes","c-reg-senators-2024","c-reg-senators-2025","c-reg-senators-2025-account","c-reg-warren-step","c-enf-flood","c-enf-hill","c-enf-doj-2016","c-enf-doj-2022","c-enf-esop","c-enf-referrals","c-syn-agreements","c-syn-structure","c-syn-ledger-gap","c-syn-2022-warnings","c-syn-sept-2023","c-syn-mercury-move","c-syn-deficit-known","c-syn-brokerage-program","c-syn-migration","c-syn-evolve-role-after","c-syn-dec-2023","c-syn-bankruptcy","c-syn-freeze","c-syn-misappropriation-claim","c-rec-ankura","c-rec-rust","c-rec-limits","c-rec-trustee-fbo","c-rec-platforms","c-rec-open-letter","c-rec-trustee-view","c-rec-shortfall","c-rec-amg-lineage","c-rec-later-dispute","c-rec-payouts-examples","c-rec-pennies","c-rec-distributions","c-rec-2026-statement","c-rec-cfpb-fund","c-lit-yotta-filed","c-lit-yotta-claims","c-lit-word-declaration","c-lit-yotta-discovery","c-lit-yotta-testimony","c-lit-colorado","c-lit-colorado-claims","c-lit-california","c-lit-tennessee","c-lit-grand-jury","c-lit-dfpi-yotta","c-lit-dave","c-lit-branch-cfpb","c-baas-origin","c-baas-vaccounts","c-baas-sub-deposit","c-baas-b9-custodial","c-baas-melio-fbo","c-baas-dave-agreement","c-baas-dave-exit","c-baas-affirm","c-baas-marqeta","c-baas-stripe-arc","c-baas-airwallex","c-baas-earnin","c-baas-branch","c-baas-usio","c-baas-dwolla","c-baas-partners-2023","c-baas-partners-2024","c-baas-partners-site","c-baas-coinstar","c-baas-solo-branch","c-baas-departures","c-baas-coastal","c-brc-attack","c-brc-data","c-brc-maine","c-brc-partners","c-brc-mdl","c-brc-settlement","c-fin-fdic-series","c-fin-2025-capital","c-fin-2026-h1","c-fin-asbd-assets","c-fin-growth-2019-2022","c-fin-q1-2022","c-fin-h1-2025","c-fin-2025-trend","c-fin-obd-reserve","c-fin-auditors","c-fin-crowe-confirmation","c-ceo-arrest","c-ceo-dismissal"],"badges":[{"label":"Federal Reserve and Arkansas cease-and-desist order (June 2024; in force)","claim_ids":["c-reg-order"],"code":"A1","category":"REGULATORY_ACTION","subject_id":"evolve"},{"label":"Flood-insurance civil money penalty (2022)","claim_ids":["c-enf-flood"],"code":"A2","category":"ENFORCEMENT","subject_id":"evolve"},{"label":"Justice Department fair-lending consent orders (2016 and 2022)","claim_ids":["c-enf-doj-2016","c-enf-doj-2022"],"code":"A4","category":"ENFORCEMENT","subject_id":"evolve"},{"label":"Labor Department ESOP fiduciary case (judgment announced 2019)","claim_ids":["c-enf-esop"],"code":"A5","category":"ENFORCEMENT","subject_id":"evolve"},{"label":"Synapse accusation of misappropriating customer funds (disputed)","claim_ids":["c-syn-misappropriation-claim"],"code":"A6","category":"ADVERSE_MEDIA","subject_id":"evolve"},{"label":"Yotta fraud suit (filed 2024; pending)","claim_ids":["c-lit-yotta-claims"],"code":"A7","category":"CIVIL_LITIGATION","subject_id":"evolve"},{"label":"Synapse end-user class actions (Colorado, from 2024; pending)","claim_ids":["c-lit-colorado"],"code":"A8","category":"CIVIL_LITIGATION","subject_id":"evolve"},{"label":"Synapse end-user class action in Tennessee (2025)","claim_ids":["c-lit-tennessee"],"code":"A9","category":"CIVIL_LITIGATION","subject_id":"evolve"},{"label":"Military Lending Act class action with Dave (2025; on appeal)","claim_ids":["c-lit-dave"],"code":"A10","category":"CIVIL_LITIGATION","subject_id":"evolve"},{"label":"Data-breach multidistrict litigation and settlement (2024-2025)","claim_ids":["c-brc-mdl"],"code":"A11","category":"CIVIL_LITIGATION","subject_id":"evolve"}],"subtype":"company","jurisdiction":"us","aliases":["First State Bank"],"identifiers":[{"scheme":"other","value":"1299","issuer":"Federal Deposit Insurance Corporation (FDIC certificate number)"},{"scheme":"other","value":"592448","issuer":"Federal Reserve System (RSSD ID)"},{"scheme":"company_register","value":"568","issuer":"Arkansas State Bank Department (state bank charter number)"},{"scheme":"company_register","value":"956221","issuer":"Mississippi Secretary of State (business ID of the foreign registration)"},{"scheme":"lei","value":"549300IRXW9RSZM2B951"}],"role":"","period":""},"reading":"Evolve Bank & Trust (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-bancorp","record":{"id":"evolve-bancorp","name":"Evolve Bancorp, Inc.","type":"organization","group":"group_companies","claim_ids":["c-id-state-charter","c-id-screening","c-grp-fdic-holding","c-grp-fed-list","c-grp-2005-purchase","c-grp-2006-structure","c-grp-2015","c-grp-2024","c-grp-2025","c-grp-shares-2022","c-grp-sblf","c-grp-owners-unknown","c-brd-kit-2024-board","c-brd-fed-signatories","c-ppl-valentine","c-ppl-bright","c-fnd-lenoir-bio","c-fnd-lenoir-other-roles","c-reg-order","c-reg-order-limits","c-reg-order-management","c-reg-order-in-force","c-lit-yotta-filed","c-lit-colorado","c-lit-california","c-lit-tennessee","c-fin-q1-2022","c-fin-bancorp-distress","c-fin-bancorp-notes"],"badges":[{"label":"Federal Reserve and Arkansas cease-and-desist order (June 2024; in force)","claim_ids":["c-reg-order"],"code":"A1","category":"REGULATORY_ACTION","subject_id":"evolve-bancorp"},{"label":"Synapse end-user class actions (Colorado, from 2024; pending)","claim_ids":["c-lit-colorado"],"code":"A8","category":"CIVIL_LITIGATION","subject_id":"evolve-bancorp"},{"label":"Reported missed note coupons and losses at the holding company (2026)","claim_ids":["c-fin-bancorp-distress"],"code":"A12","category":"FINANCIAL_DISTRESS","subject_id":"evolve-bancorp"}],"subtype":"company","jurisdiction":"us","aliases":["Parkin Bancorp, Inc.","EVOLVE BCORP INC"],"identifiers":[{"scheme":"other","value":"1142411","issuer":"Federal Reserve System (RSSD ID)"}],"role":"","period":""},"reading":"Evolve Bancorp, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-financial-group","record":{"id":"evolve-financial-group","name":"Evolve Financial Group, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-fed-list","c-grp-2005-purchase","c-grp-2006-structure","c-fnd-lenoir-other-roles"],"subtype":"company","jurisdiction":"us","identifiers":[{"scheme":"other","value":"3343351","issuer":"Federal Reserve System (RSSD ID)"}],"role":"","period":""},"reading":"Evolve Financial Group, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-commercial-finance","record":{"id":"evolve-commercial-finance","name":"Evolve Commercial Finance, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2024","c-grp-2025","c-grp-ecf-florida"],"subtype":"company","jurisdiction":"us","identifiers":[{"scheme":"company_register","value":"F18000001198","issuer":"Florida Division of Corporations (foreign corporation document number)"},{"scheme":"other","value":"81-3742575","issuer":"U.S. Internal Revenue Service (employer identification number)"}],"role":"","period":""},"reading":"Evolve Commercial Finance, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-advisors","record":{"id":"evolve-advisors","name":"Evolve Advisors, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2006-structure"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Evolve Advisors, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-benefits-group","record":{"id":"evolve-benefits-group","name":"Evolve Benefits Group, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2006-structure"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Evolve Benefits Group, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-financial-services","record":{"id":"evolve-financial-services","name":"Evolve Financial Services, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2006-structure"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Evolve Financial Services, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-mortgage-services","record":{"id":"evolve-mortgage-services","name":"Evolve Mortgage Services, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2006-structure"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Evolve Mortgage Services, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-securities","record":{"id":"evolve-securities","name":"Evolve Securities, Inc.","type":"organization","group":"group_companies","claim_ids":["c-grp-2006-structure"],"subtype":"company","jurisdiction":"us","role":"","period":""},"reading":"Evolve Securities, Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"scot-lenoir","record":{"id":"scot-lenoir","name":"B. Scot Lenoir","type":"person","group":"leadership","claim_ids":["c-grp-2005-purchase","c-grp-2006-structure","c-grp-2015","c-grp-2024","c-grp-ecf-florida","c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board","c-brd-wharton-2021","c-brd-fed-signatories","c-brd-lenoir-steps-down","c-fnd-lenoir-bio","c-fnd-lenoir-other-roles","c-fnd-kenneth","c-fnd-corkys-suit","c-offshore-evolve-assignments","c-rec-rust","c-lit-yotta-claims","c-fin-q1-2022","c-fin-crowe-confirmation"],"badges":[{"label":"Corky's 401(k) fee suit (2002; allegations, reported settled)","claim_ids":["c-fnd-corkys-suit"],"code":"A19","category":"CIVIL_LITIGATION","subject_id":"scot-lenoir"}],"subtype":"person","aliases":["Scot Lenoir","Bryan Scot Lenoir"],"role":"","period":""},"reading":"B. Scot Lenoir (person)"}
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{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"arkansas-bankers-association","record":{"id":"arkansas-bankers-association","name":"Arkansas Bankers Association","type":"organization","group":"other","claim_ids":["c-brd-freeman"],"subtype":"other","role":"","period":""},"reading":"Arkansas Bankers Association (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"klaros","record":{"id":"klaros","name":"Klaros","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-career"],"subtype":"company","role":"","period":""},"reading":"Klaros (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"jasper","record":{"id":"jasper","name":"CreditStacks (Jasper)","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-career"],"subtype":"company","aliases":["Jasper","CreditStacks"],"role":"","period":""},"reading":"CreditStacks (Jasper) (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"promontory","record":{"id":"promontory","name":"Promontory Financial Group","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-career"],"subtype":"company","role":"","period":""},"reading":"Promontory Financial Group (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"repay","record":{"id":"repay","name":"Repay Holdings Corporation","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Repay Holdings Corporation (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"thunder-bridge-iii","record":{"id":"thunder-bridge-iii","name":"Thunder Bridge Capital Partners III Inc.","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Thunder Bridge Capital Partners III Inc. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"thunder-bridge-ii","record":{"id":"thunder-bridge-ii","name":"Thunder Bridge Acquisition II, Ltd.","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Thunder Bridge Acquisition II, Ltd. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"cardworks","record":{"id":"cardworks","name":"CardWorks","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"CardWorks (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"monzo-us","record":{"id":"monzo-us","name":"Monzo US","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Monzo US (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"lending-club-am","record":{"id":"lending-club-am","name":"Lending Club Asset Management","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Lending Club Asset Management (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"higher-one","record":{"id":"higher-one","name":"Higher One Holdings","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Higher One Holdings (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"hartheimer-llc","record":{"id":"hartheimer-llc","name":"Hartheimer LLC","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-boards"],"subtype":"company","role":"","period":""},"reading":"Hartheimer LLC (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"evolve-assignments","record":{"id":"evolve-assignments","name":"Evolve Assignments Ltd.","type":"organization","group":"other","claim_ids":["c-offshore-evolve-assignments"],"subtype":"company","jurisdiction":"bb","role":"","period":""},"reading":"Evolve Assignments Ltd. (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"federal-reserve-board","record":{"id":"federal-reserve-board","name":"Board of Governors of the Federal Reserve System","type":"organization","group":"other","claim_ids":["c-reg-order","c-reg-order-in-force","c-reg-senators-2025","c-enf-flood","c-enf-hill","c-enf-doj-2022"],"subtype":"other","jurisdiction":"us","aliases":["Federal Reserve Board"],"role":"","period":""},"reading":"Board of Governors of the Federal Reserve System (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"federal-reserve-bank-st-louis","record":{"id":"federal-reserve-bank-st-louis","name":"Federal Reserve Bank of St. Louis","type":"organization","group":"other","claim_ids":["c-reg-order-findings","c-enf-referrals"],"subtype":"other","jurisdiction":"us","role":"","period":""},"reading":"Federal Reserve Bank of St. Louis (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"arkansas-state-bank-department","record":{"id":"arkansas-state-bank-department","name":"Arkansas State Bank Department","type":"organization","group":"other","claim_ids":["c-reg-order","c-reg-order-findings"],"subtype":"other","jurisdiction":"us","role":"","period":""},"reading":"Arkansas State Bank Department (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"fdic","record":{"id":"fdic","name":"Federal Deposit Insurance Corporation","type":"organization","group":"other","claim_ids":["c-ppl-hartheimer-career","c-fin-fdic-series","c-fin-2025-capital","c-fin-2026-h1"],"subtype":"other","jurisdiction":"us","aliases":["FDIC"],"role":"","period":""},"reading":"Federal Deposit Insurance Corporation (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"cfpb","record":{"id":"cfpb","name":"Consumer Financial Protection Bureau","type":"organization","group":"other","claim_ids":["c-syn-agreements","c-syn-deficit-known","c-syn-evolve-role-after","c-syn-bankruptcy","c-syn-freeze","c-rec-shortfall","c-rec-distributions","c-rec-cfpb-judgment","c-rec-cfpb-fund","c-lit-branch-cfpb","c-baas-solo-branch"],"subtype":"other","jurisdiction":"us","aliases":["CFPB"],"role":"","period":""},"reading":"Consumer Financial Protection Bureau (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"finra","record":{"id":"finra","name":"Financial Industry Regulatory Authority","type":"organization","group":"other","claim_ids":["c-syn-structure","c-syn-ledger-gap","c-syn-brokerage-program","c-syn-migration","c-syn-dec-2023","c-syn-freeze","c-lit-finra-complaint","c-lit-finra-paverman","c-lit-finra-stanley"],"subtype":"other","jurisdiction":"us","aliases":["FINRA"],"role":"","period":""},"reading":"Financial Industry Regulatory Authority (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"dfpi","record":{"id":"dfpi","name":"California Department of Financial Protection and Innovation","type":"organization","group":"other","claim_ids":["c-syn-migration","c-rec-cfpb-fund","c-lit-dfpi-yotta"],"subtype":"other","jurisdiction":"us","aliases":["DFPI"],"role":"","period":""},"reading":"California Department of Financial Protection and Innovation (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"us-doj","record":{"id":"us-doj","name":"U.S. Department of Justice","type":"organization","group":"other","claim_ids":["c-enf-doj-2016","c-enf-doj-2022"],"subtype":"other","jurisdiction":"us","role":"","period":""},"reading":"U.S. Department of Justice (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"us-dol","record":{"id":"us-dol","name":"U.S. Department of Labor","type":"organization","group":"other","claim_ids":["c-enf-esop"],"subtype":"other","jurisdiction":"us","role":"","period":""},"reading":"U.S. Department of Labor (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"entities","id":"us-treasury","record":{"id":"us-treasury","name":"U.S. Department of the Treasury","type":"organization","group":"other","claim_ids":["c-grp-sblf"],"subtype":"other","jurisdiction":"us","role":"","period":""},"reading":"U.S. Department of the Treasury (organization)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bancorp-evolve","record":{"id":"r-bancorp-evolve","from":"evolve-bancorp","to":"evolve","status":"documented","role":"Bank holding company (the bank is its principal subsidiary)","period":"Holding company of the bank since before 2005 (then Parkin Bancorp, Inc.); named in the FDIC record retrieved in October 2026","claim_ids":["c-grp-fdic-holding","c-id-state-charter","c-grp-2005-purchase","c-grp-2006-structure","c-grp-2015","c-grp-2024","c-grp-2025","c-brd-kit-2024-board","c-fin-q1-2022"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"current"},"reading":"evolve-bancorp → evolve: Bank holding company (the bank is its principal subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-bancorp","record":{"id":"r-efg-bancorp","from":"evolve-financial-group","to":"evolve-bancorp","status":"documented","role":"Bank holding company of Parkin Bancorp, Inc. (two-tier structure)","period":"Bank holding company from August 1, 2005 to December 30, 2013; parent of Parkin Bancorp as of June 30, 2006","claim_ids":["c-grp-fed-list","c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-bancorp: Bank holding company of Parkin Bancorp, Inc. (two-tier structure) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-parkin-purchase","record":{"id":"r-efg-parkin-purchase","from":"evolve-financial-group","to":"evolve-bancorp","status":"documented","role":"Proposed buyer of Parkin Bancorp, Inc. (acquisition under regulatory review)","period":"June 2005","claim_ids":["c-grp-2005-purchase"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-bancorp: Proposed buyer of Parkin Bancorp, Inc. (acquisition under regulatory review) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-evolve","record":{"id":"r-efg-evolve","from":"evolve-financial-group","to":"evolve","status":"documented","role":"Top-tier parent company (through Parkin Bancorp, Inc.)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve: Top-tier parent company (through Parkin Bancorp, Inc.) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-advisors","record":{"id":"r-efg-advisors","from":"evolve-financial-group","to":"evolve-advisors","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-advisors: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-benefits","record":{"id":"r-efg-benefits","from":"evolve-financial-group","to":"evolve-benefits-group","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-benefits-group: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-financial-services","record":{"id":"r-efg-financial-services","from":"evolve-financial-group","to":"evolve-financial-services","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-financial-services: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-mortgage","record":{"id":"r-efg-mortgage","from":"evolve-financial-group","to":"evolve-mortgage-services","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-mortgage-services: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-efg-securities","record":{"id":"r-efg-securities","from":"evolve-financial-group","to":"evolve-securities","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"evolve-financial-group → evolve-securities: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bancorp-ecf","record":{"id":"r-bancorp-ecf","from":"evolve-bancorp","to":"evolve-commercial-finance","status":"documented","role":"Parent company (listed subsidiary)","period":"As of June 30, 2024 and June 30, 2025","claim_ids":["c-grp-2024","c-grp-2025"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"evolve-bancorp → evolve-commercial-finance: Parent company (listed subsidiary) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-treasury-bancorp-sblf","record":{"id":"r-treasury-bancorp-sblf","from":"us-treasury","to":"evolve-bancorp","status":"documented","role":"Small Business Lending Fund capital provider ($4,699,000 outstanding)","period":"As of March 31, 2014","claim_ids":["c-grp-sblf"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"us-treasury → evolve-bancorp: Small Business Lending Fund capital provider ($4,699,000 outstanding) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-clanton-evolve-shares","record":{"id":"r-clanton-evolve-shares","from":"donald-clanton","to":"evolve","status":"documented","role":"Minor stockholder (self-reported)","period":"Since 2005","claim_ids":["c-grp-minor-holder"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"unknown"},"reading":"donald-clanton → evolve: Minor stockholder (self-reported) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-bancorp-codef","record":{"id":"r-evolve-bancorp-codef","from":"evolve","to":"evolve-bancorp","status":"documented","role":"Co-respondents to the 2024 cease-and-desist order and co-defendants in suits by Yotta and Synapse end users","period":"From June 2024 (order); suits from September 2024; Yotta dismissed its claims against Evolve Bancorp on January 23, 2025","claim_ids":["c-reg-order","c-lit-yotta-filed","c-lit-colorado","c-lit-california","c-lit-tennessee"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"unknown"},"reading":"evolve → evolve-bancorp: Co-respondents to the 2024 cease-and-desist order and co-defendants in suits by Yotta and Synapse end users [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-csc-evolve-agent","record":{"id":"r-csc-evolve-agent","from":"corporation-service-company","to":"evolve","status":"documented","role":"Registered agent in Mississippi","period":"As of the 2022 annual report","claim_ids":["c-id-mississippi"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"corporation-service-company → evolve: Registered agent in Mississippi [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-csc-ecf-agent","record":{"id":"r-csc-ecf-agent","from":"corporation-service-company","to":"evolve-commercial-finance","status":"documented","role":"Registered agent in Florida","period":"As of the 2023 annual report","claim_ids":["c-grp-ecf-florida"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"corporation-service-company → evolve-commercial-finance: Registered agent in Florida [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-evolve-chair","record":{"id":"r-lenoir-evolve-chair","from":"scot-lenoir","to":"evolve","status":"documented","role":"Chairman of the board (director)","period":"From 2005, when a group he led acquired the bank, to July 2024; chairman in the regulator reports as of June 30, 2006 to June 30, 2024","claim_ids":["c-brd-lenoir-steps-down","c-grp-2005-purchase","c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-mississippi-2022","c-brd-kit-2024-board","c-brd-wharton-2021","c-brd-fed-signatories","c-fin-crowe-confirmation","c-fnd-lenoir-other-roles","c-lit-yotta-claims"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → evolve: Chairman of the board (director) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-evolve-founder","record":{"id":"r-lenoir-evolve-founder","from":"scot-lenoir","to":"evolve","status":"documented","role":"Founder; remained involved in day-to-day operations after leaving the chair (per a bank spokesperson)","period":"From July 2024; spoke for the bank as founder on October 23, 2024","claim_ids":["c-brd-lenoir-steps-down","c-rec-rust","c-brd-kit-2024-board"],"kind":"other","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"scot-lenoir → evolve: Founder; remained involved in day-to-day operations after leaving the chair (per a bank spokesperson) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-bancorp-chair","record":{"id":"r-lenoir-bancorp-chair","from":"scot-lenoir","to":"evolve-bancorp","status":"documented","role":"Chairman of the board","period":"Listed as chairman as of June 30, 2006 (then Parkin Bancorp), 2015 and 2024 and in the June 2024 order; signed the June 2022 shareholder letter","claim_ids":["c-grp-2006-structure","c-grp-2015","c-grp-2024","c-brd-fed-signatories","c-fin-q1-2022"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → evolve-bancorp: Chairman of the board [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-bancorp-founder","record":{"id":"r-lenoir-bancorp-founder","from":"scot-lenoir","to":"evolve-bancorp","status":"documented","role":"Founder and chief executive officer","period":"Raised its initial capital after the 2000 sale of First Mercantile; founder in 2004 (aggregator); chief executive as of the 2024 kit","claim_ids":["c-fnd-lenoir-bio","c-fnd-lenoir-other-roles","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"scot-lenoir → evolve-bancorp: Founder and chief executive officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-efg","record":{"id":"r-lenoir-efg","from":"scot-lenoir","to":"evolve-financial-group","status":"documented","role":"Organizer and founder; chairman and chief executive","period":"Formed in January 2004; chairman and chief executive as of June 30, 2006","claim_ids":["c-grp-2005-purchase","c-grp-2006-structure","c-fnd-lenoir-other-roles"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → evolve-financial-group: Organizer and founder; chairman and chief executive [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-ecf","record":{"id":"r-lenoir-ecf","from":"scot-lenoir","to":"evolve-commercial-finance","status":"documented","role":"Director","period":"As of the 2023 Florida annual report","claim_ids":["c-grp-ecf-florida"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"scot-lenoir → evolve-commercial-finance: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-american-trust","record":{"id":"r-lenoir-american-trust","from":"scot-lenoir","to":"american-trust-co","status":"reported","role":"Former president and chief executive (aggregator profile)","period":"Undated earlier role","claim_ids":["c-fnd-lenoir-other-roles"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → american-trust-co: Former president and chief executive (aggregator profile) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-afs","record":{"id":"r-lenoir-afs","from":"scot-lenoir","to":"afs-investment-advisors","status":"reported","role":"Former president and director (aggregator profile)","period":"Undated earlier role","claim_ids":["c-fnd-lenoir-other-roles"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → afs-investment-advisors: Former president and director (aggregator profile) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-fmt","record":{"id":"r-lenoir-fmt","from":"scot-lenoir","to":"first-mercantile","status":"documented","role":"President, later chief executive and president","period":"Before the 2000 sale; named as president in the suit filed December 2002 (reported January 2003)","claim_ids":["c-fnd-lenoir-bio","c-fnd-kenneth","c-fnd-corkys-suit"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → first-mercantile: President, later chief executive and president [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-kenneth-fmt","record":{"id":"r-kenneth-fmt","from":"kenneth-lenoir","to":"first-mercantile","status":"documented","role":"Chief executive (\"the elder Lenoir's firm\")","period":"From at least January 1994; named as chief executive in the December 2002 suit","claim_ids":["c-fnd-kenneth","c-fnd-corkys-suit"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"kenneth-lenoir → first-mercantile: Chief executive (\"the elder Lenoir's firm\") [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-kenneth-scot-family","record":{"id":"r-kenneth-scot-family","from":"kenneth-lenoir","to":"scot-lenoir","status":"reported","role":"Father","period":"Undated","claim_ids":["c-fnd-kenneth"],"kind":"family","direction":"directed","role_group":"associations","temporal_status":"unknown"},"reading":"kenneth-lenoir → scot-lenoir: Father [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-kenneth-evolve-evp","record":{"id":"r-kenneth-evolve-evp","from":"kenneth-lenoir","to":"evolve","status":"documented","role":"Executive vice president","period":"As of June 30, 2006","claim_ids":["c-brd-2006","c-fnd-kenneth"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"kenneth-lenoir → evolve: Executive vice president [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-kenneth-evolve-trust","record":{"id":"r-kenneth-evolve-trust","from":"kenneth-lenoir","to":"evolve","status":"reported","role":"Handled the trust-business transaction behind the Labor Department's ESOP case (as reported)","period":"Transaction of December 2010; case reported as a 2016 case","claim_ids":["c-enf-referrals"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"kenneth-lenoir → evolve: Handled the trust-business transaction behind the Labor Department's ESOP case (as reported) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-ncf-fmt","record":{"id":"r-ncf-fmt","from":"national-commerce-financial","to":"first-mercantile","status":"documented","role":"Acquirer and parent company (through FMT Holding Company)","period":"Acquisition approved June 20, 2000; parent until the 2004 SunTrust merger","claim_ids":["c-fnd-fmt-sale","c-fnd-lenoir-bio","c-fnd-corkys-suit"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"national-commerce-financial → first-mercantile: Acquirer and parent company (through FMT Holding Company) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-ncf-nbc","record":{"id":"r-ncf-nbc","from":"national-commerce-financial","to":"national-bank-of-commerce","status":"documented","role":"Parent company","period":"As of the December 2002 suit","claim_ids":["c-fnd-corkys-suit"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"national-commerce-financial → national-bank-of-commerce: Parent company [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-ncf-usi","record":{"id":"r-ncf-usi","from":"national-commerce-financial","to":"usi-alliance","status":"documented","role":"Parent company (subsidiary named in the 2004 merger application)","period":"As of 2004","claim_ids":["c-ppl-holland-companies"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"national-commerce-financial → usi-alliance: Parent company (subsidiary named in the 2004 merger application) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-suntrust-ncf","record":{"id":"r-suntrust-ncf","from":"suntrust-banks","to":"national-commerce-financial","status":"documented","role":"Merger partner; applied to acquire its subsidiaries","period":"2004","claim_ids":["c-fnd-fmt-sale","c-ppl-holland-companies"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"suntrust-banks → national-commerce-financial: Merger partner; applied to acquire its subsidiaries [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-corkys-scot","record":{"id":"r-corkys-scot","from":"corkys","to":"scot-lenoir","status":"reported","role":"Plaintiff (with its owners) in a fiduciary-duty and racketeering suit naming him as First Mercantile's president","period":"Filed December 2002; reported settled","claim_ids":["c-fnd-corkys-suit"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"corkys → scot-lenoir: Plaintiff (with its owners) in a fiduciary-duty and racketeering suit naming him as First Mercantile's president [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-corkys-kenneth","record":{"id":"r-corkys-kenneth","from":"corkys","to":"kenneth-lenoir","status":"reported","role":"Plaintiff (with its owners) in a fiduciary-duty and racketeering suit naming him as First Mercantile's chief executive","period":"Filed December 2002; reported settled","claim_ids":["c-fnd-corkys-suit"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"corkys → kenneth-lenoir: Plaintiff (with its owners) in a fiduciary-duty and racketeering suit naming him as First Mercantile's chief executive [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-corkys-fmt","record":{"id":"r-corkys-fmt","from":"corkys","to":"first-mercantile","status":"reported","role":"Plaintiff (with its owners) in a fiduciary-duty and racketeering suit over 401(k) plan fees","period":"Filed December 2002; reported settled","claim_ids":["c-fnd-corkys-suit"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"corkys → first-mercantile: Plaintiff (with its owners) in a fiduciary-duty and racketeering suit over 401(k) plan fees [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-corkys-nbc","record":{"id":"r-corkys-nbc","from":"corkys","to":"national-bank-of-commerce","status":"reported","role":"Plaintiff (with its owners) in a fiduciary-duty and racketeering suit over 401(k) plan fees","period":"Filed December 2002; reported settled","claim_ids":["c-fnd-corkys-suit"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"corkys → national-bank-of-commerce: Plaintiff (with its owners) in a fiduciary-duty and racketeering suit over 401(k) plan fees [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lenoir-evolve-assignments","record":{"id":"r-lenoir-evolve-assignments","from":"scot-lenoir","to":"evolve-assignments","status":"hypothesis","role":"Director, if the offshore-database record 'Lenoir Bryan Scott' is the bank's founder (identity not established)","period":"May 26, 2009 to September 10, 2014","claim_ids":["c-offshore-evolve-assignments"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scot-lenoir → evolve-assignments: Director, if the offshore-database record 'Lenoir Bryan Scott' is the bank's founder (identity not established) [hypothesis]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-evolve-assignments","record":{"id":"r-stafford-evolve-assignments","from":"scott-stafford","to":"evolve-assignments","status":"hypothesis","role":"Director, if the offshore-database record 'Stafford William Scott' is the bank's former chief executive (identity not established)","period":"May 26, 2009 to September 10, 2014","claim_ids":["c-offshore-evolve-assignments"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → evolve-assignments: Director, if the offshore-database record 'Stafford William Scott' is the bank's former chief executive (identity not established) [hypothesis]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-evolve-ceo","record":{"id":"r-stafford-evolve-ceo","from":"scott-stafford","to":"evolve","status":"documented","role":"President and chief executive officer","period":"Chief executive as of June 30, 2006; president and chief executive until he stepped away from day-to-day operations in February 2025; retired in 2025","claim_ids":["c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-kit-2024-board","c-brd-fed-signatories","c-brd-feb-2025-memo","c-brd-stafford-retired","c-reg-senators-2024","c-enf-flood"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → evolve: President and chief executive officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-evolve-director","record":{"id":"r-stafford-evolve-director","from":"scott-stafford","to":"evolve","status":"documented","role":"Director","period":"Listed as of June 30, 2006 to June 30, 2024; not listed as of June 30, 2025","claim_ids":["c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-kit-2024-board","c-brd-2025"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-bancorp-sec","record":{"id":"r-stafford-bancorp-sec","from":"scott-stafford","to":"evolve-bancorp","status":"documented","role":"Secretary","period":"As of June 30, 2006 (then Parkin Bancorp), 2015 and 2024","claim_ids":["c-grp-2006-structure","c-grp-2015","c-grp-2024"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"scott-stafford → evolve-bancorp: Secretary [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-efg-sec","record":{"id":"r-stafford-efg-sec","from":"scott-stafford","to":"evolve-financial-group","status":"documented","role":"Secretary","period":"As of June 30, 2006","claim_ids":["c-grp-2006-structure"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → evolve-financial-group: Secretary [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-ecf","record":{"id":"r-stafford-ecf","from":"scott-stafford","to":"evolve-commercial-finance","status":"documented","role":"President","period":"As of the 2023 Florida annual report","claim_ids":["c-grp-ecf-florida"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"scott-stafford → evolve-commercial-finance: President [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-nbc","record":{"id":"r-stafford-nbc","from":"scott-stafford","to":"national-bank-of-commerce","status":"documented","role":"Senior vice president","period":"Before joining Evolve","claim_ids":["c-ppl-stafford"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → national-bank-of-commerce: Senior vice president [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stafford-duncan","record":{"id":"r-stafford-duncan","from":"scott-stafford","to":"duncan-williams","status":"documented","role":"Investment banker","period":"Before joining Evolve","claim_ids":["c-ppl-stafford"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"scott-stafford → duncan-williams: Investment banker [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-evolve-ceo","record":{"id":"r-hartheimer-evolve-ceo","from":"robert-hartheimer","to":"evolve","status":"documented","role":"Chief executive officer","period":"August 13, 2025 until his termination after his arrest on October 23, 2025","claim_ids":["c-brd-hartheimer-appointed","c-brd-johnston","c-brd-after-hartheimer","c-ppl-hartheimer-career","c-fin-h1-2025","c-ceo-arrest","c-ceo-dismissal"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → evolve: Chief executive officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-evolve-cfo","record":{"id":"r-mosteller-evolve-cfo","from":"mark-mosteller","to":"evolve","status":"documented","role":"Executive vice president and chief financial officer","period":"Joined in 2015; executive vice president and chief financial officer as of June 30, 2023 and 2024 and in the 2022 Mississippi report","claim_ids":["c-ppl-mosteller","c-brd-kit-2024-management","c-brd-2023-2024","c-brd-mississippi-2022","c-rec-pennies"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"mark-mosteller → evolve: Executive vice president and chief financial officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-evolve-president","record":{"id":"r-mosteller-evolve-president","from":"mark-mosteller","to":"evolve","status":"documented","role":"President and chief financial officer","period":"From February 2025; with the general counsel ran the bank after October 2025","claim_ids":["c-brd-feb-2025-memo","c-brd-2025","c-brd-hartheimer-appointed","c-brd-after-hartheimer"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"mark-mosteller → evolve: President and chief financial officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-bancorp","record":{"id":"r-mosteller-bancorp","from":"mark-mosteller","to":"evolve-bancorp","status":"documented","role":"Chief financial officer","period":"As of June 30, 2025","claim_ids":["c-grp-2025"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"mark-mosteller → evolve-bancorp: Chief financial officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-ecf","record":{"id":"r-mosteller-ecf","from":"mark-mosteller","to":"evolve-commercial-finance","status":"documented","role":"Treasurer","period":"As of the 2023 Florida annual report","claim_ids":["c-grp-ecf-florida"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"mark-mosteller → evolve-commercial-finance: Treasurer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-gtx","record":{"id":"r-mosteller-gtx","from":"mark-mosteller","to":"gtx","status":"documented","role":"Executive vice president and chief financial officer","period":"Before 2015","claim_ids":["c-ppl-mosteller"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"mark-mosteller → gtx: Executive vice president and chief financial officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-upm","record":{"id":"r-mosteller-upm","from":"mark-mosteller","to":"union-planters-mortgage","status":"documented","role":"Chief operating officer","period":"Earlier career","claim_ids":["c-ppl-mosteller"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"mark-mosteller → union-planters-mortgage: Chief operating officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mosteller-ankura","record":{"id":"r-mosteller-ankura","from":"mark-mosteller","to":"ankura","status":"reported","role":"Oversaw its reconciliation of Synapse end-user funds for the bank (as reported)","period":"Reported in February 2025","claim_ids":["c-rec-pennies"],"kind":"other","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"mark-mosteller → ankura: Oversaw its reconciliation of Synapse end-user funds for the bank (as reported) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-weltzin-evolve","record":{"id":"r-weltzin-evolve","from":"joelle-weltzin","to":"evolve","status":"documented","role":"General counsel and corporate secretary (executive vice president from February 2025)","period":"Joined in March 2024; executive vice president from February 2025; with the president ran the bank after October 2025","claim_ids":["c-brd-kit-2024-management","c-brd-feb-2025-memo","c-brd-2025","c-brd-hartheimer-appointed","c-brd-after-hartheimer"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"joelle-weltzin → evolve: General counsel and corporate secretary (executive vice president from February 2025) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-word-evolve-cto","record":{"id":"r-word-evolve-cto","from":"hank-word","to":"evolve","status":"documented","role":"Chief technology officer (the bank's first)","period":"Joined in 2014; chief technology officer at the time of the wire-screening coding error","claim_ids":["c-brd-kit-2024-management","c-reg-coding-error","c-brd-feb-2025-memo"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"hank-word → evolve: Chief technology officer (the bank's first) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-word-evolve-obd","record":{"id":"r-word-evolve-obd","from":"hank-word","to":"evolve","status":"documented","role":"President of the Open Banking Division (executive vice president from February 2025)","period":"Joined in 2014; president of Open Banking by June 2022; executive vice president from February 2025; left in September 2025","claim_ids":["c-brd-kit-2024-management","c-baas-marqeta","c-brd-feb-2025-memo","c-brd-2025","c-brd-hartheimer-appointed","c-brd-word-leaves","c-lit-yotta-claims","c-lit-word-declaration","c-lit-yotta-testimony"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"hank-word → evolve: President of the Open Banking Division (executive vice president from February 2025) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-word-tabapay","record":{"id":"r-word-tabapay","from":"hank-word","to":"tabapay","status":"reported","role":"Current company on his public professional profile","period":"As of the retained profile","claim_ids":["c-ppl-word-tabapay"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"hank-word → tabapay: Current company on his public professional profile [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-moenickheim-evolve","record":{"id":"r-moenickheim-evolve","from":"peter-moenickheim","to":"evolve","status":"documented","role":"Chief risk officer","period":"From February 2024 (notice to the Federal Reserve); listed in the 2024 kit","claim_ids":["c-brd-cro-notice","c-brd-kit-2024-management"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"peter-moenickheim → evolve: Chief risk officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holmes-evolve","record":{"id":"r-holmes-evolve","from":"thomas-holmes","to":"evolve","status":"documented","role":"Chief marketing and communications officer","period":"Until he stepped away, dated October 2024 by an online encyclopedia","claim_ids":["c-brd-kit-2024-management","c-brd-holmes"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"thomas-holmes → evolve: Chief marketing and communications officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-ducklo-evolve","record":{"id":"r-ducklo-evolve","from":"robert-ducklo","to":"evolve","status":"documented","role":"General counsel and corporate secretary","period":"Joined in 2022; listed in the 2023 kit","claim_ids":["c-brd-kit-2023"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-ducklo → evolve: General counsel and corporate secretary [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-russell-evolve","record":{"id":"r-russell-evolve","from":"cecilia-russell","to":"evolve","status":"documented","role":"Senior vice president and chief compliance officer","period":"As of the 2023 kit","claim_ids":["c-brd-kit-2023"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"cecilia-russell → evolve: Senior vice president and chief compliance officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-staab-evolve","record":{"id":"r-staab-evolve","from":"christopher-staab","to":"evolve","status":"documented","role":"Chief technology officer","period":"As of the 2024 kit; described as former chief technology officer by December 2025","claim_ids":["c-brd-kit-2024-management","c-lit-yotta-testimony"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"christopher-staab → evolve: Chief technology officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bedsole-evolve","record":{"id":"r-bedsole-evolve","from":"robin-bedsole","to":"evolve","status":"documented","role":"Controller","period":"At the bank since 2016; listed as of June 30, 2023 and 2024","claim_ids":["c-brd-2023-2024","c-brd-kit-2023"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robin-bedsole → evolve: Controller [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bedsole-bancorp","record":{"id":"r-bedsole-bancorp","from":"robin-bedsole","to":"evolve-bancorp","status":"documented","role":"Controller","period":"As of June 30, 2024","claim_ids":["c-grp-2024"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robin-bedsole → evolve-bancorp: Controller [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-freeman-evolve","record":{"id":"r-freeman-evolve","from":"john-freeman","to":"evolve","status":"documented","role":"President of the Banking Division (president in the 2022 Mississippi report)","period":"Of Evolve on the State Banking Board until December 31, 2015; president in 2022; Banking Division president in the 2023 and 2024 kits","claim_ids":["c-brd-freeman","c-brd-mississippi-2022","c-brd-kit-2024-management"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"john-freeman → evolve: President of the Banking Division (president in the 2022 Mississippi report) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-reynolds-evolve","record":{"id":"r-reynolds-evolve","from":"randy-reynolds","to":"evolve","status":"documented","role":"President of the Arkansas Banking Division","period":"As of the 2024 kit","claim_ids":["c-brd-kit-2024-management"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"randy-reynolds → evolve: President of the Arkansas Banking Division [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-barham-evolve","record":{"id":"r-barham-evolve","from":"henry-barham","to":"evolve","status":"documented","role":"Secretary","period":"As of the 2022 Mississippi annual report","claim_ids":["c-brd-mississippi-2022"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"henry-barham → evolve: Secretary [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-barham-ecf","record":{"id":"r-barham-ecf","from":"henry-barham","to":"evolve-commercial-finance","status":"documented","role":"Secretary (signed the 2023 Florida annual report)","period":"March 5, 2023","claim_ids":["c-grp-ecf-florida"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"henry-barham → evolve-commercial-finance: Secretary (signed the 2023 Florida annual report) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-johnston-evolve","record":{"id":"r-johnston-evolve","from":"alex-johnston","to":"evolve","status":"documented","role":"Senior vice president and head of Open Banking","period":"From October 2, 2025","claim_ids":["c-brd-johnston","c-brd-no-new-ceo"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"alex-johnston → evolve: Senior vice president and head of Open Banking [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-duke-evolve","record":{"id":"r-duke-evolve","from":"arlon-duke","to":"evolve","status":"documented","role":"Senior vice president and chief technology officer","period":"From February 3, 2026","claim_ids":["c-brd-after-hartheimer","c-brd-no-new-ceo"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"arlon-duke → evolve: Senior vice president and chief technology officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-clanton-evolve-sba","record":{"id":"r-clanton-evolve-sba","from":"donald-clanton","to":"evolve","status":"documented","role":"Former president of the SBA Lending Division","period":"Before the 2024 kit (undated)","claim_ids":["c-brd-kit-2024-board","c-ppl-clanton"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"donald-clanton → evolve: Former president of the SBA Lending Division [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-copeland-evolve","record":{"id":"r-copeland-evolve","from":"john-copeland","to":"evolve","status":"documented","role":"Executive vice president and chief financial officer","period":"As of June 30, 2015","claim_ids":["c-brd-2015"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"john-copeland → evolve: Executive vice president and chief financial officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-cooper-evolve","record":{"id":"r-cooper-evolve","from":"john-cooper","to":"evolve","status":"documented","role":"President","period":"As of June 30, 2006","claim_ids":["c-brd-2006"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"john-cooper → evolve: President [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-jenkins-evolve-division","record":{"id":"r-jenkins-evolve-division","from":"forrest-jenkins","to":"evolve","status":"documented","role":"President of the Arkansas Banking Division (recruited while a director)","period":"Undated (obituary)","claim_ids":["c-brd-jenkins"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"forrest-jenkins → evolve: President of the Arkansas Banking Division (recruited while a director) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-aaron-hill-evolve","record":{"id":"r-aaron-hill-evolve","from":"aaron-hill","to":"evolve","status":"documented","role":"Former employee; managed a mortgage loan production office in Louisville","period":"From at least October 2017 to November 2018 (named as a former employee in May 2020)","claim_ids":["c-enf-hill"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"aaron-hill → evolve: Former employee; managed a mortgage loan production office in Louisville [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-jessica-hill-evolve","record":{"id":"r-jessica-hill-evolve","from":"jessica-hill","to":"evolve","status":"documented","role":"Former employee paid by the Louisville loan production office","period":"From at least October 2017 to November 2018 (named as a former employee in May 2020)","claim_ids":["c-enf-hill"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"jessica-hill → evolve: Former employee paid by the Louisville loan production office [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-valentine-evolve-chair","record":{"id":"r-valentine-evolve-chair","from":"steve-valentine","to":"evolve","status":"documented","role":"Chairman of the board","period":"By August 13, 2025","claim_ids":["c-brd-hartheimer-appointed"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"steve-valentine → evolve: Chairman of the board [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-valentine-evolve","record":{"id":"r-valentine-evolve","from":"steve-valentine","to":"evolve","status":"documented","role":"Director","period":"Listed as of June 30, 2006 to June 30, 2025","claim_ids":["c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"steve-valentine → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-valentine-bancorp","record":{"id":"r-valentine-bancorp","from":"steve-valentine","to":"evolve-bancorp","status":"documented","role":"Director; chairman as of June 30, 2025","period":"Director in the 2024 kit; chairman in 2025","claim_ids":["c-ppl-valentine","c-brd-kit-2024-board","c-grp-2025"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"steve-valentine → evolve-bancorp: Director; chairman as of June 30, 2025 [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-valentine-ibm","record":{"id":"r-valentine-ibm","from":"steve-valentine","to":"ibm","status":"documented","role":"Executive","period":"Earlier career","claim_ids":["c-ppl-valentine"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steve-valentine → ibm: Executive [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-valentine-autozone","record":{"id":"r-valentine-autozone","from":"steve-valentine","to":"autozone","status":"documented","role":"Senior vice president of business development and chief information officer","period":"Earlier career","claim_ids":["c-ppl-valentine"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"steve-valentine → autozone: Senior vice president of business development and chief information officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bright-evolve","record":{"id":"r-bright-evolve","from":"al-bright","to":"evolve","status":"documented","role":"Director","period":"From 2015 (law-firm profile); listed as of June 30, 2015 to June 30, 2025","claim_ids":["c-ppl-bright","c-brd-director-tenures","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"al-bright → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bright-bancorp","record":{"id":"r-bright-bancorp","from":"al-bright","to":"evolve-bancorp","status":"documented","role":"Vice chairman","period":"As of June 30, 2025","claim_ids":["c-grp-2025","c-ppl-bright"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"al-bright → evolve-bancorp: Vice chairman [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-bright-bass-berry","record":{"id":"r-bright-bass-berry","from":"al-bright","to":"bass-berry-sims","status":"documented","role":"Member of the law firm (Memphis)","period":"As of the retained firm profile","claim_ids":["c-ppl-bright"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"al-bright → bass-berry-sims: Member of the law firm (Memphis) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-clanton-evolve","record":{"id":"r-clanton-evolve","from":"donald-clanton","to":"evolve","status":"documented","role":"Director","period":"From 2005; listed as of June 30, 2006 to June 30, 2025","claim_ids":["c-grp-minor-holder","c-brd-director-tenures","c-ppl-clanton","c-brd-2006","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"donald-clanton → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-clanton-duncan","record":{"id":"r-clanton-duncan","from":"donald-clanton","to":"duncan-williams","status":"documented","role":"Executive vice president of debt capital markets, later chief operating officer","period":"Registered February 2002 to January 2018; retired as chief operating officer in 2017","claim_ids":["c-ppl-clanton"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"donald-clanton → duncan-williams: Executive vice president of debt capital markets, later chief operating officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-clanton-cic","record":{"id":"r-clanton-cic","from":"donald-clanton","to":"commerce-investment-corp","status":"documented","role":"President","period":"Earlier career","claim_ids":["c-ppl-clanton"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"donald-clanton → commerce-investment-corp: President [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-nbc-cic","record":{"id":"r-nbc-cic","from":"national-bank-of-commerce","to":"commerce-investment-corp","status":"documented","role":"Parent company","period":"Undated (2024 kit biography)","claim_ids":["c-ppl-clanton"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"national-bank-of-commerce → commerce-investment-corp: Parent company [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-evolve","record":{"id":"r-holland-evolve","from":"lewis-holland","to":"evolve","status":"documented","role":"Director","period":"Listed as of June 30, 2015 to June 30, 2025; a director in 2013 per Buckeye","claim_ids":["c-brd-director-tenures","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"lewis-holland → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-rjfp","record":{"id":"r-holland-rjfp","from":"lewis-holland","to":"raymond-james-financial-products","status":"documented","role":"Director","period":"As of the 2024 kit","claim_ids":["c-ppl-holland"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"lewis-holland → raymond-james-financial-products: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-usi","record":{"id":"r-holland-usi","from":"lewis-holland","to":"usi-alliance","status":"documented","role":"Director","period":"As of the 2024 kit","claim_ids":["c-ppl-holland"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"lewis-holland → usi-alliance: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-turley","record":{"id":"r-holland-turley","from":"lewis-holland","to":"henry-turley","status":"documented","role":"President (also described as president and chief operating officer)","period":"2001 to September 2009","claim_ids":["c-ppl-holland"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lewis-holland → henry-turley: President (also described as president and chief operating officer) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-ncf","record":{"id":"r-holland-ncf","from":"lewis-holland","to":"national-commerce-financial","status":"documented","role":"Vice chairman and chief financial officer; president of its financial enterprise businesses","period":"Before 2001 (from 1994 per an aggregator profile)","claim_ids":["c-ppl-holland"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lewis-holland → national-commerce-financial: Vice chairman and chief financial officer; president of its financial enterprise businesses [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-holland-buckeye","record":{"id":"r-holland-buckeye","from":"lewis-holland","to":"buckeye","status":"documented","role":"Director","period":"September 2005 to August 2013","claim_ids":["c-ppl-holland"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"lewis-holland → buckeye: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-magness-evolve","record":{"id":"r-magness-evolve","from":"lon-magness","to":"evolve","status":"documented","role":"Director","period":"Listed as of June 30, 2015 to June 30, 2025","claim_ids":["c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"lon-magness → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-magness-reliant","record":{"id":"r-magness-reliant","from":"lon-magness","to":"reliant-investment-management","status":"documented","role":"Principal and chief compliance officer","period":"As of the retained firm page","claim_ids":["c-ppl-magness"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"lon-magness → reliant-investment-management: Principal and chief compliance officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-pitts-evolve","record":{"id":"r-pitts-evolve","from":"john-pitts","to":"evolve","status":"documented","role":"Director","period":"Since January 1, 2008; listed as of June 30, 2015 to June 30, 2025","claim_ids":["c-brd-director-tenures","c-brd-2015","c-brd-2023-2024","c-brd-2025","c-brd-mississippi-2022","c-brd-kit-2024-board"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"john-pitts → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-pitts-stifel","record":{"id":"r-pitts-stifel","from":"john-pitts","to":"stifel","status":"documented","role":"Registered representative (Memphis)","period":"Since June 5, 2015","claim_ids":["c-ppl-pitts","c-fin-bancorp-notes"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"john-pitts → stifel: Registered representative (Memphis) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-pitts-nbc","record":{"id":"r-pitts-nbc","from":"john-pitts","to":"national-bank-of-commerce","status":"documented","role":"Executive vice president, capital markets group","period":"Earlier career","claim_ids":["c-ppl-pitts"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"john-pitts → national-bank-of-commerce: Executive vice president, capital markets group [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-wharton-evolve","record":{"id":"r-wharton-evolve","from":"monica-wharton","to":"evolve","status":"documented","role":"Director","period":"Appointed October 12, 2021; listed as of June 30, 2023 and 2024; not listed as of June 30, 2025","claim_ids":["c-brd-wharton-2021","c-brd-kit-2023","c-brd-2023-2024","c-brd-2025"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"monica-wharton → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-wharton-methodist","record":{"id":"r-wharton-methodist","from":"monica-wharton","to":"methodist-le-bonheur","status":"documented","role":"Executive vice president and chief operating officer (earlier chief administrative officer and chief legal officer)","period":"Chief legal officer 2017 to 2020; chief administrative officer 2020 to 2023; later chief operating officer","claim_ids":["c-ppl-wharton","c-brd-wharton-2021","c-brd-kit-2023"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"current"},"reading":"monica-wharton → methodist-le-bonheur: Executive vice president and chief operating officer (earlier chief administrative officer and chief legal officer) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-wharton-regional-one","record":{"id":"r-wharton-regional-one","from":"monica-wharton","to":"regional-one-health","status":"documented","role":"Chief legal officer and general counsel","period":"Before 2017","claim_ids":["c-ppl-wharton"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"monica-wharton → regional-one-health: Chief legal officer and general counsel [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-jenkins-evolve","record":{"id":"r-jenkins-evolve","from":"forrest-jenkins","to":"evolve","status":"documented","role":"Director","period":"As of June 30, 2015","claim_ids":["c-brd-2015","c-brd-jenkins"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"forrest-jenkins → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-jenkins-citizens","record":{"id":"r-jenkins-citizens","from":"forrest-jenkins","to":"citizens-bank-marion","status":"documented","role":"Chairman and president","period":"Earlier career (obituary)","claim_ids":["c-brd-jenkins"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"forrest-jenkins → citizens-bank-marion: Chairman and president [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-freeman-liberty","record":{"id":"r-freeman-liberty","from":"john-freeman","to":"liberty-bank","status":"documented","role":"President","period":"Before joining Evolve","claim_ids":["c-brd-freeman"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"john-freeman → liberty-bank: President [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-freeman-aba","record":{"id":"r-freeman-aba","from":"john-freeman","to":"arkansas-bankers-association","status":"documented","role":"Chairman of the board","period":"As of the 2023 and 2024 kits","claim_ids":["c-brd-freeman"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"john-freeman → arkansas-bankers-association: Chairman of the board [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-cooper-evolve-director","record":{"id":"r-cooper-evolve-director","from":"john-cooper","to":"evolve","status":"documented","role":"Director","period":"As of June 30, 2006","claim_ids":["c-brd-2006"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"john-cooper → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-dehart-evolve","record":{"id":"r-dehart-evolve","from":"j-de-dehart","to":"evolve","status":"documented","role":"Director","period":"As of June 30, 2006","claim_ids":["c-brd-2006"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"j-de-dehart → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-saig-evolve","record":{"id":"r-saig-evolve","from":"victor-saig","to":"evolve","status":"documented","role":"Director","period":"As of June 30, 2006","claim_ids":["c-brd-2006"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"victor-saig → evolve: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-klaros","record":{"id":"r-hartheimer-klaros","from":"robert-hartheimer","to":"klaros","status":"documented","role":"Senior adviser","period":"Before August 2025","claim_ids":["c-ppl-hartheimer-career"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → klaros: Senior adviser [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-jasper","record":{"id":"r-hartheimer-jasper","from":"robert-hartheimer","to":"jasper","status":"documented","role":"Co-founder and chief regulatory officer","period":"2015 to 2020","claim_ids":["c-ppl-hartheimer-career"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → jasper: Co-founder and chief regulatory officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-promontory","record":{"id":"r-hartheimer-promontory","from":"robert-hartheimer","to":"promontory","status":"documented","role":"Managing director","period":"2002 to 2008","claim_ids":["c-ppl-hartheimer-career"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → promontory: Managing director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-fdic","record":{"id":"r-hartheimer-fdic","from":"robert-hartheimer","to":"fdic","status":"documented","role":"Official; helped create the Division of Resolutions and later directed it","period":"From 1991","claim_ids":["c-ppl-hartheimer-career"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → fdic: Official; helped create the Division of Resolutions and later directed it [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-repay","record":{"id":"r-hartheimer-repay","from":"robert-hartheimer","to":"repay","status":"documented","role":"Director","period":"Since June 2018 (as of the 2021 proxy)","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robert-hartheimer → repay: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-tb3","record":{"id":"r-hartheimer-tb3","from":"robert-hartheimer","to":"thunder-bridge-iii","status":"documented","role":"Director and audit committee chairman","period":"Since February 2021 (as of the 2021 proxy)","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robert-hartheimer → thunder-bridge-iii: Director and audit committee chairman [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-cardworks","record":{"id":"r-hartheimer-cardworks","from":"robert-hartheimer","to":"cardworks","status":"documented","role":"Independent director","period":"Since 2017 (as of the 2021 proxy)","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robert-hartheimer → cardworks: Independent director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-monzo","record":{"id":"r-hartheimer-monzo","from":"robert-hartheimer","to":"monzo-us","status":"documented","role":"Organizer and director nominee","period":"From December 2019","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robert-hartheimer → monzo-us: Organizer and director nominee [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-llc","record":{"id":"r-hartheimer-llc","from":"robert-hartheimer","to":"hartheimer-llc","status":"documented","role":"Founder and managing member","period":"Since 2008 (as of the 2021 proxy)","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"robert-hartheimer → hartheimer-llc: Founder and managing member [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-tb2","record":{"id":"r-hartheimer-tb2","from":"robert-hartheimer","to":"thunder-bridge-ii","status":"documented","role":"Director","period":"2019 to June 2021","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → thunder-bridge-ii: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-lcam","record":{"id":"r-hartheimer-lcam","from":"robert-hartheimer","to":"lending-club-am","status":"documented","role":"Director","period":"2016 to 2019","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → lending-club-am: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-hartheimer-higher-one","record":{"id":"r-hartheimer-higher-one","from":"robert-hartheimer","to":"higher-one","status":"documented","role":"Director","period":"2012 to 2016","claim_ids":["c-ppl-hartheimer-boards"],"kind":"directs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"robert-hartheimer → higher-one: Director [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-synapse-evolve-services","record":{"id":"r-synapse-evolve-services","from":"synapse","to":"evolve","status":"documented","role":"Technology intermediary for the bank's fintech programmes, keeping the end-user ledgers (Bank Services Agreement)","period":"From April 18, 2017 (master agreement September 23, 2022); agreement expired September 2023 with a wind-down until the May 2024 shutdown","claim_ids":["c-syn-agreements","c-syn-structure","c-syn-evolve-role-after","c-syn-dec-2023","c-syn-freeze","c-reg-senators-2024","c-lit-grand-jury","c-lit-colorado-claims","c-fin-auditors","c-rec-cfpb-fund","c-lit-dfpi-yotta"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"synapse → evolve: Technology intermediary for the bank's fintech programmes, keeping the end-user ledgers (Bank Services Agreement) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-synapse-dispute","record":{"id":"r-evolve-synapse-dispute","from":"evolve","to":"synapse","status":"documented","role":"Dispute over missing end-user funds, ledgers and fees (each blamed the other)","period":"From August 2022 (notice of intent to end the relationship) and the September 2023 breach notice; unresolved in August 2025","claim_ids":["c-reg-senators-2025-account","c-syn-2022-warnings","c-syn-ledger-gap","c-syn-sept-2023","c-syn-deficit-known","c-syn-bankruptcy","c-syn-misappropriation-claim","c-rec-limits"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"historical"},"reading":"evolve → synapse: Dispute over missing end-user funds, ledgers and fees (each blamed the other) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-sb-program","record":{"id":"r-evolve-sb-program","from":"evolve","to":"synapse-brokerage","status":"documented","role":"Deposit bank feeding its cash management program: end-user funds swept onward from October 2023, incoming funds held in Synapse-titled accounts from December 2023","period":"October 2023 to the May 11, 2024 freeze","claim_ids":["c-syn-brokerage-program","c-syn-migration","c-syn-evolve-role-after","c-syn-dec-2023","c-syn-freeze"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → synapse-brokerage: Deposit bank feeding its cash management program: end-user funds swept onward from October 2023, incoming funds held in Synapse-titled accounts from December 2023 [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-sb-reconciliation","record":{"id":"r-evolve-sb-reconciliation","from":"evolve","to":"synapse-brokerage","status":"documented","role":"Held, reconciled and paid out funds of its end users after the freeze","period":"From the May 2024 freeze; payments from November 2024; further distributions announced January 8, 2026","claim_ids":["c-rec-ankura","c-rec-rust","c-rec-2026-statement"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → synapse-brokerage: Held, reconciled and paid out funds of its end users after the freeze [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-synapse-sb","record":{"id":"r-synapse-sb","from":"synapse","to":"synapse-brokerage","status":"documented","role":"Parent company (sole owner)","period":"From its acquisition in July 2020","claim_ids":["c-syn-company","c-syn-brokerage-program"],"kind":"owns","direction":"directed","role_group":"ownership","temporal_status":"historical"},"reading":"synapse → synapse-brokerage: Parent company (sole owner) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-pathak-synapse","record":{"id":"r-pathak-synapse","from":"sankaet-pathak","to":"synapse","status":"documented","role":"Founder and chief executive officer","period":"Founder; chief executive through the 2023 dispute","claim_ids":["c-syn-company","c-syn-sept-2023","c-syn-board-pathak","c-syn-mercury-move"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"sankaet-pathak → synapse: Founder and chief executive officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-mercury-synapse","record":{"id":"r-mercury-synapse","from":"mercury","to":"synapse","status":"reported","role":"Fintech client (about 35% of its business, per Pathak) until moving to the bank directly","period":"Until September 2023","claim_ids":["c-syn-mercury-move"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"mercury → synapse: Fintech client (about 35% of its business, per Pathak) until moving to the bank directly [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stanley-sb","record":{"id":"r-stanley-sb","from":"jeffrey-stanley","to":"synapse-brokerage","status":"documented","role":"President and chief executive officer","period":"Registered February 2023 to June 2024; controlled its cash management program from September 2023 to May 2024","claim_ids":["c-lit-finra-complaint","c-lit-finra-stanley"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"jeffrey-stanley → synapse-brokerage: President and chief executive officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-paverman-sb","record":{"id":"r-paverman-sb","from":"mark-paverman","to":"synapse-brokerage","status":"documented","role":"Chief compliance officer","period":"Registered January 2021 to January 2025","claim_ids":["c-lit-finra-complaint","c-lit-finra-paverman"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"mark-paverman → synapse-brokerage: Chief compliance officer [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-sb-finra-member","record":{"id":"r-sb-finra-member","from":"synapse-brokerage","to":"finra","status":"documented","role":"Member firm (as MVP Global Trading, LLC until its 2020 acquisition)","period":"From March 2006","claim_ids":["c-syn-brokerage-program"],"kind":"other","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"synapse-brokerage → finra: Member firm (as MVP Global Trading, LLC until its 2020 acquisition) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-finra-stanley","record":{"id":"r-finra-stanley","from":"finra","to":"jeffrey-stanley","status":"documented","role":"Disciplinary complaint; settled with suspensions","period":"Complaint August 28, 2025; settled May 22, 2026","claim_ids":["c-lit-finra-complaint","c-lit-finra-stanley"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"finra → jeffrey-stanley: Disciplinary complaint; settled with suspensions [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-finra-paverman","record":{"id":"r-finra-paverman","from":"finra","to":"mark-paverman","status":"documented","role":"Disciplinary complaint; settled with a $20,000 fine and 12-month principal suspension","period":"Complaint August 28, 2025; settled January 28, 2026","claim_ids":["c-lit-finra-complaint","c-lit-finra-paverman"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"finra → mark-paverman: Disciplinary complaint; settled with a $20,000 fine and 12-month principal suspension [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-cfpb-synapse","record":{"id":"r-cfpb-synapse","from":"cfpb","to":"synapse","status":"documented","role":"Sued it in its bankruptcy case; stipulated final judgment with a $1 civil money penalty","period":"Filed August 21, 2025; judgment entered September 12, 2025","claim_ids":["c-rec-cfpb-judgment","c-rec-cfpb-fund"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"cfpb → synapse: Sued it in its bankruptcy case; stipulated final judgment with a $1 civil money penalty [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-amg-synapse","record":{"id":"r-amg-synapse","from":"amg-national-trust","to":"synapse","status":"documented","role":"Partner bank holding Synapse end users' funds","period":"Until the May 2024 freeze","claim_ids":["c-rec-trustee-fbo","c-lit-colorado-claims"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"amg-national-trust → synapse: Partner bank holding Synapse end users' funds [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-lineage-synapse","record":{"id":"r-lineage-synapse","from":"lineage-bank","to":"synapse","status":"documented","role":"Partner bank holding Synapse end users' funds","period":"Until the May 2024 freeze","claim_ids":["c-rec-trustee-fbo","c-lit-colorado-claims"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"lineage-bank → synapse: Partner bank holding Synapse end users' funds [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-american-bank-synapse","record":{"id":"r-american-bank-synapse","from":"american-bank","to":"synapse","status":"documented","role":"Partner bank holding Synapse end users' funds","period":"Until the May 2024 freeze","claim_ids":["c-rec-trustee-fbo","c-lit-colorado-claims"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"american-bank → synapse: Partner bank holding Synapse end users' funds [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-amg","record":{"id":"r-evolve-amg","from":"evolve","to":"amg-national-trust","status":"documented","role":"Fellow Synapse partner bank: counterparty to Synapse-related transfers and to the dispute over where missing end-user funds are","period":"Transfers before the May 2024 freeze; dispute from November 2024","claim_ids":["c-rec-amg-lineage","c-rec-open-letter","c-rec-later-dispute"],"kind":"business","direction":"undirected","role_group":"business","temporal_status":"historical"},"reading":"evolve → amg-national-trust: Fellow Synapse partner bank: counterparty to Synapse-related transfers and to the dispute over where missing end-user funds are [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-lineage","record":{"id":"r-evolve-lineage","from":"evolve","to":"lineage-bank","status":"documented","role":"Fellow Synapse partner bank: counterparty to Synapse-related transfers and to the dispute over where missing end-user funds are","period":"Transfers before the May 2024 freeze; dispute from November 2024","claim_ids":["c-rec-amg-lineage","c-rec-open-letter","c-rec-later-dispute"],"kind":"business","direction":"undirected","role_group":"business","temporal_status":"historical"},"reading":"evolve → lineage-bank: Fellow Synapse partner bank: counterparty to Synapse-related transfers and to the dispute over where missing end-user funds are [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-amg-codef","record":{"id":"r-evolve-amg-codef","from":"evolve","to":"amg-national-trust","status":"documented","role":"Co-defendants in the Synapse end-user class actions (Colorado; California case transferred there)","period":"From November 2024; pending in 2026","claim_ids":["c-lit-colorado","c-lit-california","c-lit-colorado-claims"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"current"},"reading":"evolve → amg-national-trust: Co-defendants in the Synapse end-user class actions (Colorado; California case transferred there) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-lineage-codef","record":{"id":"r-evolve-lineage-codef","from":"evolve","to":"lineage-bank","status":"documented","role":"Co-defendants in the Synapse end-user class actions (Colorado, California and Tennessee)","period":"From November 2024; pending in 2026","claim_ids":["c-lit-colorado","c-lit-california","c-lit-tennessee","c-lit-colorado-claims"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"current"},"reading":"evolve → lineage-bank: Co-defendants in the Synapse end-user class actions (Colorado, California and Tennessee) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-american-bank-codef","record":{"id":"r-evolve-american-bank-codef","from":"evolve","to":"american-bank","status":"documented","role":"Co-defendants in the Synapse end-user class actions (Colorado; California case transferred there)","period":"From November 2024; pending in 2026","claim_ids":["c-lit-colorado","c-lit-california","c-lit-colorado-claims"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"current"},"reading":"evolve → american-bank: Co-defendants in the Synapse end-user class actions (Colorado; California case transferred there) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-ankura","record":{"id":"r-evolve-ankura","from":"evolve","to":"ankura","status":"documented","role":"Engaged it to reconcile funds held for Synapse end users","period":"Reconciliation completed October 18, 2024; review continued into January 2026","claim_ids":["c-rec-ankura","c-rec-limits","c-rec-rust","c-rec-pennies","c-rec-2026-statement","c-lit-yotta-testimony"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → ankura: Engaged it to reconcile funds held for Synapse end users [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-rust","record":{"id":"r-evolve-rust","from":"evolve","to":"rust-consulting","status":"documented","role":"Engaged it to administer payments to Synapse Brokerage end users","period":"Announced October 23, 2024","claim_ids":["c-rec-rust"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → rust-consulting: Engaged it to administer payments to Synapse Brokerage end users [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-yotta","record":{"id":"r-evolve-yotta","from":"evolve","to":"yotta","status":"documented","role":"Partner bank holding its customers' funds through Synapse (Evolve routing and account numbers)","period":"From at least 2020 to the May 2024 freeze","claim_ids":["c-lit-dfpi-yotta","c-rec-platforms","c-syn-migration","c-rec-amg-lineage","c-rec-payouts-examples"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → yotta: Partner bank holding its customers' funds through Synapse (Evolve routing and account numbers) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-yotta-synapse","record":{"id":"r-yotta-synapse","from":"yotta","to":"synapse","status":"documented","role":"Fintech client of its 'banking as a service' platform","period":"Until the April 2024 bankruptcy","claim_ids":["c-lit-dfpi-yotta"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"yotta → synapse: Fintech client of its 'banking as a service' platform [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-yotta-evolve-suit","record":{"id":"r-yotta-evolve-suit","from":"yotta","to":"evolve","status":"documented","role":"Plaintiff in a fraud suit (N.D. Cal. No. 3:24-cv-06456)","period":"Filed September 13, 2024; pending in 2026","claim_ids":["c-lit-yotta-filed","c-lit-yotta-claims","c-lit-word-declaration","c-lit-yotta-discovery","c-lit-yotta-testimony"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"yotta → evolve: Plaintiff in a fraud suit (N.D. Cal. No. 3:24-cv-06456) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-yotta-bancorp-suit","record":{"id":"r-yotta-bancorp-suit","from":"yotta","to":"evolve-bancorp","status":"documented","role":"Plaintiff (claims against the holding company dismissed by stipulation)","period":"September 13, 2024 to January 23, 2025","claim_ids":["c-lit-yotta-filed"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"yotta → evolve-bancorp: Plaintiff (claims against the holding company dismissed by stipulation) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-moelis-yotta","record":{"id":"r-moelis-yotta","from":"adam-moelis","to":"yotta","status":"documented","role":"Co-founder, former chief executive and director (signed the 2026 consent order)","period":"As of May 15, 2026","claim_ids":["c-lit-dfpi-yotta","c-lit-yotta-claims"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"unknown"},"reading":"adam-moelis → yotta: Co-founder, former chief executive and director (signed the 2026 consent order) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-dfpi-yotta","record":{"id":"r-dfpi-yotta","from":"dfpi","to":"yotta","status":"documented","role":"Consent order (desist and refrain; $1,000,000 penalty)","period":"May 15, 2026","claim_ids":["c-lit-dfpi-yotta","c-rec-cfpb-fund"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"dfpi → yotta: Consent order (desist and refrain; $1,000,000 penalty) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-juno","record":{"id":"r-evolve-juno","from":"evolve","to":"juno","status":"documented","role":"Bank holding its users' funds through Synapse","period":"Until the May 2024 freeze","claim_ids":["c-rec-platforms"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → juno: Bank holding its users' funds through Synapse [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-yieldstreet","record":{"id":"r-evolve-yieldstreet","from":"evolve","to":"yieldstreet","status":"documented","role":"Bank holding its users' funds through Synapse","period":"Until the May 2024 freeze","claim_ids":["c-rec-platforms"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → yieldstreet: Bank holding its users' funds through Synapse [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-clerkie","record":{"id":"r-evolve-clerkie","from":"evolve","to":"clerkie","status":"documented","role":"Bank holding its users' funds through Synapse","period":"Until the May 2024 freeze","claim_ids":["c-rec-platforms"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → clerkie: Bank holding its users' funds through Synapse [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-mercury","record":{"id":"r-evolve-mercury","from":"evolve","to":"mercury","status":"documented","role":"Partner bank (through Synapse, then directly from about October 2023)","period":"Directly from 2023; Mercury announced its move to other banks in March 2025, to finish by the end of 2025","claim_ids":["c-baas-origin","c-syn-mercury-move","c-baas-departures","c-brc-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → mercury: Partner bank (through Synapse, then directly from about October 2023) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-branch","record":{"id":"r-evolve-branch","from":"evolve","to":"branch","status":"documented","role":"Partner bank providing the deposit account in the Branch Account","period":"From January 2020; listed on the bank website in 2026","claim_ids":["c-baas-branch","c-baas-origin","c-baas-partners-2023","c-baas-partners-2024","c-baas-partners-site","c-baas-solo-branch","c-lit-branch-cfpb"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"evolve → branch: Partner bank providing the deposit account in the Branch Account [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-marqeta","record":{"id":"r-evolve-marqeta","from":"evolve","to":"marqeta","status":"documented","role":"Issuing bank supporting card programmes on its platform","period":"From 2022 (announced partnership)","claim_ids":["c-baas-marqeta","c-baas-origin","c-baas-partners-2024","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → marqeta: Issuing bank supporting card programmes on its platform [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-stripe","record":{"id":"r-evolve-stripe","from":"evolve","to":"stripe","status":"documented","role":"Bank holding Stripe Treasury funds","period":"As of the 2023 kit and the retained Stripe guide","claim_ids":["c-baas-stripe-arc","c-baas-origin","c-baas-partners-2023"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → stripe: Bank holding Stripe Treasury funds [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-arc","record":{"id":"r-evolve-arc","from":"evolve","to":"arc","status":"documented","role":"Bank holding its virtual treasury accounts (through Stripe Treasury)","period":"As of the retained Stripe guide","claim_ids":["c-baas-stripe-arc"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → arc: Bank holding its virtual treasury accounts (through Stripe Treasury) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-affirm","record":{"id":"r-evolve-affirm","from":"evolve","to":"affirm","status":"documented","role":"Sole issuing bank for the Affirm Card under a loan program agreement","period":"Initial two-year term expired in 2023; renews annually (as of the fiscal 2025 report)","claim_ids":["c-baas-affirm","c-baas-partners-2024","c-baas-partners-site","c-brc-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"evolve → affirm: Sole issuing bank for the Affirm Card under a loan program agreement [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-airwallex","record":{"id":"r-evolve-airwallex","from":"evolve","to":"airwallex","status":"documented","role":"Bank providing domestic payment services to Airwallex's US customers","period":"As of the retained service agreement; listed in the 2024 kit","claim_ids":["c-baas-airwallex","c-baas-partners-2024","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → airwallex: Bank providing domestic payment services to Airwallex's US customers [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-wise","record":{"id":"r-evolve-wise","from":"evolve","to":"wise","status":"reported","role":"Partner bank; Wise's customers were affected by the 2024 breach (per an online encyclopedia)","period":"2024","claim_ids":["c-brc-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → wise: Partner bank; Wise's customers were affected by the 2024 breach (per an online encyclopedia) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-dave","record":{"id":"r-evolve-dave","from":"evolve","to":"dave","status":"documented","role":"Partner bank under a Bank Services Agreement and Debit Card Issuing Agreement","period":"From July 13, 2020; members moving to Coastal Community Bank, expected to be substantially complete by the end of 2026","claim_ids":["c-baas-dave-agreement","c-baas-dave-exit","c-baas-partners-2024","c-baas-departures","c-brc-partners"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"evolve → dave: Partner bank under a Bank Services Agreement and Debit Card Issuing Agreement [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-dave-operating","record":{"id":"r-evolve-dave-operating","from":"evolve","to":"dave-operating","status":"documented","role":"Counterparty to the amendment of the Bank Services Agreement","period":"August 8, 2024","claim_ids":["c-baas-dave-agreement"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → dave-operating: Counterparty to the amendment of the Bank Services Agreement [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-coastal-dave","record":{"id":"r-coastal-dave","from":"coastal-community-bank","to":"dave","status":"documented","role":"Partner bank for all new members (concurrent programme with Evolve)","period":"As of the 2025 annual report","claim_ids":["c-baas-dave-exit"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"coastal-community-bank → dave: Partner bank for all new members (concurrent programme with Evolve) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-coastal-evolve","record":{"id":"r-coastal-evolve","from":"coastal-community-bank","to":"evolve","status":"documented","role":"Prospective buyer of assets and deposits of BaaS programmes (non-binding term sheet; no longer pursued)","period":"April 29, 2026 to July 2026","claim_ids":["c-baas-coastal"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"coastal-community-bank → evolve: Prospective buyer of assets and deposits of BaaS programmes (non-binding term sheet; no longer pursued) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-melio","record":{"id":"r-evolve-melio","from":"evolve","to":"melio","status":"documented","role":"Bank provider holding master accounts for the benefit of Melio's customers","period":"As of the 2023 terms of service; listed in 2024","claim_ids":["c-baas-melio-fbo","c-baas-partners-2023","c-baas-partners-2024","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → melio: Bank provider holding master accounts for the benefit of Melio's customers [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-earnin","record":{"id":"r-evolve-earnin","from":"evolve","to":"earnin","status":"documented","role":"Partner bank for Early Pay deposit accounts","period":"As of the retained product page","claim_ids":["c-baas-earnin","c-baas-partners-2023","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → earnin: Partner bank for Early Pay deposit accounts [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-sila","record":{"id":"r-evolve-sila","from":"evolve","to":"sila","status":"documented","role":"Partner bank whose customer account agreement Sila publishes","period":"As of the 2023 kit and the retained agreement","claim_ids":["c-baas-sub-deposit","c-baas-partners-2023"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → sila: Partner bank whose customer account agreement Sila publishes [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-dwolla","record":{"id":"r-evolve-dwolla","from":"evolve","to":"dwolla","status":"documented","role":"Partner bank whose account terms Dwolla publishes for its clients' virtual account numbers","period":"Terms last updated August 1, 2021","claim_ids":["c-baas-sub-deposit","c-baas-dwolla"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → dwolla: Partner bank whose account terms Dwolla publishes for its clients' virtual account numbers [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-b9","record":{"id":"r-evolve-b9","from":"evolve","to":"b9","status":"documented","role":"Bank under the account and cardholder agreement for B9 customers","period":"Agreement effective March 27, 2026","claim_ids":["c-baas-b9-custodial","c-baas-departures"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"evolve → b9: Bank under the account and cardholder agreement for B9 customers [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-step","record":{"id":"r-evolve-step","from":"evolve","to":"step","status":"documented","role":"Partner bank for banking services","period":"As of 2026","claim_ids":["c-reg-warren-step","c-baas-departures","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"current"},"reading":"evolve → step: Partner bank for banking services [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-mbanq","record":{"id":"r-evolve-mbanq","from":"evolve","to":"mbanq","status":"reported","role":"Partner (middleware platform) still working with the bank","period":"As reported in February 2026","claim_ids":["c-baas-departures"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → mbanq: Partner (middleware platform) still working with the bank [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-solo","record":{"id":"r-evolve-solo","from":"evolve","to":"solo-funds","status":"reported","role":"Partner bank (per the senators' letter)","period":"As of April 2025","claim_ids":["c-baas-solo-branch"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → solo-funds: Partner bank (per the senators' letter) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-bond","record":{"id":"r-evolve-bond","from":"evolve","to":"bond","status":"documented","role":"Shown among partners in the 2024 Investor Relations kit","period":"As of the 2024 kit","claim_ids":["c-baas-partners-2024"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → bond: Shown among partners in the 2024 Investor Relations kit [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-prizepool","record":{"id":"r-evolve-prizepool","from":"evolve","to":"prizepool","status":"documented","role":"Shown among partners in the 2023 Investor Relations kit","period":"As of the 2023 kit","claim_ids":["c-baas-partners-2023"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → prizepool: Shown among partners in the 2023 Investor Relations kit [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-uphold","record":{"id":"r-evolve-uphold","from":"evolve","to":"uphold","status":"documented","role":"Shown among partners in the 2023 Investor Relations kit","period":"As of the 2023 kit","claim_ids":["c-baas-partners-2023"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → uphold: Shown among partners in the 2023 Investor Relations kit [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-usio","record":{"id":"r-evolve-usio","from":"evolve","to":"usio","status":"documented","role":"Sponsor bank for PINless debit processing","period":"From 2018 until TransPecos Bank took over sponsorship in 2023","claim_ids":["c-baas-usio"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → usio: Sponsor bank for PINless debit processing [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-tabapay","record":{"id":"r-evolve-tabapay","from":"evolve","to":"tabapay","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site","c-baas-coinstar"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → tabapay: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-coinstar-evolve","record":{"id":"r-coinstar-evolve","from":"coinstar","to":"evolve","status":"documented","role":"Transfer to Account service expanded with TabaPay and Evolve (bank news item)","period":"Undated news item","claim_ids":["c-baas-coinstar"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"coinstar → evolve: Transfer to Account service expanded with TabaPay and Evolve (bank news item) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-coinstar-tabapay","record":{"id":"r-coinstar-tabapay","from":"coinstar","to":"tabapay","status":"documented","role":"Transfer to Account service expanded with TabaPay and Evolve (bank news item)","period":"Undated news item","claim_ids":["c-baas-coinstar"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"coinstar → tabapay: Transfer to Account service expanded with TabaPay and Evolve (bank news item) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-flute","record":{"id":"r-evolve-flute","from":"evolve","to":"flute","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → flute: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-luqra","record":{"id":"r-evolve-luqra","from":"evolve","to":"luqra","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → luqra: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-netevia","record":{"id":"r-evolve-netevia","from":"evolve","to":"netevia","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → netevia: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-rain","record":{"id":"r-evolve-rain","from":"evolve","to":"rain","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → rain: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-split-pay","record":{"id":"r-evolve-split-pay","from":"evolve","to":"split-pay","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → split-pay: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-viva","record":{"id":"r-evolve-viva","from":"evolve","to":"viva-finance","status":"documented","role":"Listed Open Banking partner","period":"As of the retained website copy","claim_ids":["c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → viva-finance: Listed Open Banking partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-visa","record":{"id":"r-evolve-visa","from":"evolve","to":"visa","status":"documented","role":"Principal member of the card network (Open Banking business); listed as a partner","period":"As of the 2024 kit and the retained website copy","claim_ids":["c-baas-vaccounts","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → visa: Principal member of the card network (Open Banking business); listed as a partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-mastercard","record":{"id":"r-evolve-mastercard","from":"evolve","to":"mastercard","status":"documented","role":"Principal member of the card network (Open Banking business); listed as a partner","period":"As of the 2024 kit and the retained website copy","claim_ids":["c-baas-vaccounts","c-baas-partners-site"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"evolve → mastercard: Principal member of the card network (Open Banking business); listed as a partner [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-dave-codef","record":{"id":"r-evolve-dave-codef","from":"evolve","to":"dave","status":"documented","role":"Co-defendants and joint appellants in a Military Lending Act class action (C.D. Cal. No. 2:25-cv-04029)","period":"Filed April 1, 2025; appealed December 26, 2025","claim_ids":["c-lit-dave"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"current"},"reading":"evolve → dave: Co-defendants and joint appellants in a Military Lending Act class action (C.D. Cal. No. 2:25-cv-04029) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-affirm-mdl","record":{"id":"r-evolve-affirm-mdl","from":"evolve","to":"affirm","status":"documented","role":"Co-defendants in the data-breach litigation (MDL No. 3127)","period":"From October 2024","claim_ids":["c-brc-mdl"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"unknown"},"reading":"evolve → affirm: Co-defendants in the data-breach litigation (MDL No. 3127) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-branch-mdl","record":{"id":"r-evolve-branch-mdl","from":"evolve","to":"branch","status":"documented","role":"Co-defendants in the data-breach litigation (MDL No. 3127)","period":"From October 2024","claim_ids":["c-brc-mdl"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"unknown"},"reading":"evolve → branch: Co-defendants in the data-breach litigation (MDL No. 3127) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-capitalj-mdl","record":{"id":"r-evolve-capitalj-mdl","from":"evolve","to":"capitalj","status":"documented","role":"Co-defendants in the data-breach litigation (MDL No. 3127)","period":"From October 2024","claim_ids":["c-brc-mdl"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"unknown"},"reading":"evolve → capitalj: Co-defendants in the data-breach litigation (MDL No. 3127) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-yotta-mdl","record":{"id":"r-evolve-yotta-mdl","from":"evolve","to":"yotta","status":"documented","role":"Co-defendants in the data-breach litigation (MDL No. 3127)","period":"From October 2024","claim_ids":["c-brc-mdl"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"unknown"},"reading":"evolve → yotta: Co-defendants in the data-breach litigation (MDL No. 3127) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-cfpb-branch","record":{"id":"r-cfpb-branch","from":"cfpb","to":"branch","status":"documented","role":"Sued it with Walmart over Branch Accounts for delivery drivers (D. Minn. No. 24-cv-4610)","period":"Filed December 23, 2024","claim_ids":["c-lit-branch-cfpb","c-baas-solo-branch"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"unknown"},"reading":"cfpb → branch: Sued it with Walmart over Branch Accounts for delivery drivers (D. Minn. No. 24-cv-4610) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-cfpb-solo","record":{"id":"r-cfpb-solo","from":"cfpb","to":"solo-funds","status":"reported","role":"Sued it for predatory lending (per the senators' letter)","period":"Before April 2025","claim_ids":["c-baas-solo-branch"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"unknown"},"reading":"cfpb → solo-funds: Sued it for predatory lending (per the senators' letter) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-evolve-order","record":{"id":"r-frb-evolve-order","from":"federal-reserve-board","to":"evolve","status":"documented","role":"Cease-and-desist order upon consent (jointly with the Arkansas State Bank Department)","period":"Effective June 11, 2024; no termination announced by October 16, 2026","claim_ids":["c-reg-order","c-reg-order-in-force"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"federal-reserve-board → evolve: Cease-and-desist order upon consent (jointly with the Arkansas State Bank Department) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-bancorp-order","record":{"id":"r-frb-bancorp-order","from":"federal-reserve-board","to":"evolve-bancorp","status":"documented","role":"Cease-and-desist order upon consent (jointly with the Arkansas State Bank Department)","period":"Effective June 11, 2024; no termination announced by October 16, 2026","claim_ids":["c-reg-order","c-reg-order-in-force"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"federal-reserve-board → evolve-bancorp: Cease-and-desist order upon consent (jointly with the Arkansas State Bank Department) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-asbd-evolve-order","record":{"id":"r-asbd-evolve-order","from":"arkansas-state-bank-department","to":"evolve","status":"documented","role":"Cease-and-desist order upon consent (jointly with the Federal Reserve Board)","period":"Effective June 11, 2024","claim_ids":["c-reg-order"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"arkansas-state-bank-department → evolve: Cease-and-desist order upon consent (jointly with the Federal Reserve Board) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-asbd-bancorp-order","record":{"id":"r-asbd-bancorp-order","from":"arkansas-state-bank-department","to":"evolve-bancorp","status":"documented","role":"Cease-and-desist order upon consent (jointly with the Federal Reserve Board)","period":"Effective June 11, 2024","claim_ids":["c-reg-order"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"current"},"reading":"arkansas-state-bank-department → evolve-bancorp: Cease-and-desist order upon consent (jointly with the Federal Reserve Board) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frbstl-evolve-exams","record":{"id":"r-frbstl-evolve-exams","from":"federal-reserve-bank-st-louis","to":"evolve","status":"documented","role":"Supervising Reserve Bank; its examinations found the deficiencies recited in the 2024 order","period":"Examinations issued August 11, 2023, August 30, 2023 and January 10, 2024","claim_ids":["c-reg-order-findings"],"kind":"other","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-bank-st-louis → evolve: Supervising Reserve Bank; its examinations found the deficiencies recited in the 2024 order [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-asbd-evolve-exams","record":{"id":"r-asbd-evolve-exams","from":"arkansas-state-bank-department","to":"evolve","status":"documented","role":"State supervisor; joint safety-and-soundness examination","period":"Examination issued August 11, 2023","claim_ids":["c-reg-order-findings"],"kind":"other","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"arkansas-state-bank-department → evolve: State supervisor; joint safety-and-soundness examination [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frbstl-evolve-referrals","record":{"id":"r-frbstl-evolve-referrals","from":"federal-reserve-bank-st-louis","to":"evolve","status":"reported","role":"Referred the bank to the Justice Department three times over mortgage discrimination (as reported)","period":"Over ten years (as reported)","claim_ids":["c-enf-referrals"],"kind":"other","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-bank-st-louis → evolve: Referred the bank to the Justice Department three times over mortgage discrimination (as reported) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-evolve-referral-2019","record":{"id":"r-frb-evolve-referral-2019","from":"federal-reserve-board","to":"evolve","status":"documented","role":"Referred the bank to the Justice Department over mortgage pricing","period":"February 8, 2019","claim_ids":["c-enf-doj-2022"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-board → evolve: Referred the bank to the Justice Department over mortgage pricing [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-evolve-flood","record":{"id":"r-frb-evolve-flood","from":"federal-reserve-board","to":"evolve","status":"documented","role":"Civil money penalty of $13,950 under the National Flood Insurance Act (consent order)","period":"Effective June 15, 2022","claim_ids":["c-enf-flood"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-board → evolve: Civil money penalty of $13,950 under the National Flood Insurance Act (consent order) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-aaron-hill","record":{"id":"r-frb-aaron-hill","from":"federal-reserve-board","to":"aaron-hill","status":"documented","role":"Consent order of prohibition","period":"Effective May 26, 2020","claim_ids":["c-enf-hill"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-board → aaron-hill: Consent order of prohibition [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-frb-jessica-hill","record":{"id":"r-frb-jessica-hill","from":"federal-reserve-board","to":"jessica-hill","status":"documented","role":"Consent order of prohibition","period":"Effective May 26, 2020","claim_ids":["c-enf-hill"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"federal-reserve-board → jessica-hill: Consent order of prohibition [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-doj-evolve","record":{"id":"r-doj-evolve","from":"us-doj","to":"evolve","status":"documented","role":"Plaintiff in fair-lending suits resolved by consent orders (W.D. Tenn. Nos. 2:16-cv-2040 and 2:22-cv-02667)","period":"January 21, 2016 and September to October 2022","claim_ids":["c-enf-doj-2016","c-enf-doj-2022"],"kind":"legal","direction":"directed","role_group":"legal","temporal_status":"historical"},"reading":"us-doj → evolve: Plaintiff in fair-lending suits resolved by consent orders (W.D. Tenn. Nos. 2:16-cv-2040 and 2:22-cv-02667) [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-sentry","record":{"id":"r-evolve-sentry","from":"evolve","to":"sentry-equipment","status":"documented","role":"Transactional fiduciary of its employee stock ownership plan","period":"December 2010 transaction; ordered in August 2019 to restore $6,502,500 to the plan","claim_ids":["c-enf-esop"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"evolve → sentry-equipment: Transactional fiduciary of its employee stock ownership plan [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-evolve-vinoskey","record":{"id":"r-evolve-vinoskey","from":"evolve","to":"adam-vinoskey","status":"documented","role":"Jointly ordered to restore $6,502,500 to the Sentry ESOP","period":"Announced August 2019","claim_ids":["c-enf-esop"],"kind":"legal","direction":"undirected","role_group":"legal","temporal_status":"historical"},"reading":"evolve → adam-vinoskey: Jointly ordered to restore $6,502,500 to the Sentry ESOP [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-vinoskey-sentry","record":{"id":"r-vinoskey-sentry","from":"adam-vinoskey","to":"sentry-equipment","status":"documented","role":"Former chief executive and selling shareholder","period":"December 2010 transaction","claim_ids":["c-enf-esop"],"kind":"employs","direction":"directed","role_group":"people","temporal_status":"historical"},"reading":"adam-vinoskey → sentry-equipment: Former chief executive and selling shareholder [documented]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-crowe-evolve","record":{"id":"r-crowe-evolve","from":"crowe","to":"evolve","status":"reported","role":"External auditor (unqualified opinions)","period":"2021 to 2023 audits","claim_ids":["c-fin-auditors","c-fin-crowe-confirmation"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"crowe → evolve: External auditor (unqualified opinions) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-kpmg-evolve","record":{"id":"r-kpmg-evolve","from":"kpmg","to":"evolve","status":"reported","role":"External auditor (unqualified opinion)","period":"2024 audit","claim_ids":["c-fin-auditors"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"kpmg → evolve: External auditor (unqualified opinion) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-crowe-synapse","record":{"id":"r-crowe-synapse","from":"crowe","to":"synapse","status":"reported","role":"Requested confirmation of Synapse's cash balances at the bank for the 2023 audit","period":"February 2024","claim_ids":["c-fin-crowe-confirmation"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"historical"},"reading":"crowe → synapse: Requested confirmation of Synapse's cash balances at the bank for the 2023 audit [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"relationships","id":"r-stifel-bancorp","record":{"id":"r-stifel-bancorp","from":"stifel","to":"evolve-bancorp","status":"reported","role":"Broker soliciting bids for two tranches of its notes at 40 cents on the dollar (as reported)","period":"Early 2026","claim_ids":["c-fin-bancorp-notes"],"kind":"business","direction":"directed","role_group":"business","temporal_status":"unknown"},"reading":"stifel → evolve-bancorp: Broker soliciting bids for two tranches of its notes at 40 cents on the dollar (as reported) [reported]"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-1925-charter","record":{"id":"e-1925-charter","date":"1925-06-05","title":"First State Bank is chartered in Arkansas (later Evolve Bank & Trust)","claim_ids":["c-id-fdic-record","c-id-state-charter"]},"reading":"1925-06-05 First State Bank is chartered in Arkansas (later Evolve Bank & Trust)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2005-rename","record":{"id":"e-2005-rename","date":"2005","title":"A group led by Scot Lenoir buys the bank, which is renamed Evolve Bank & Trust","claim_ids":["c-id-name-history","c-grp-2005-purchase"]},"reading":"2005 A group led by Scot Lenoir buys the bank, which is renamed Evolve Bank & Trust"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2016-doj","record":{"id":"e-2016-doj","date":"2016-01-21","title":"Court enters a fair-lending consent order in a Justice Department case against the bank","claim_ids":["c-enf-doj-2016"]},"reading":"2016-01-21 Court enters a fair-lending consent order in a Justice Department case against the bank"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2017-synapse","record":{"id":"e-2017-synapse","date":"2017-04-18","title":"Bank Services Agreement with Synapse Financial Technologies","claim_ids":["c-syn-agreements"]},"reading":"2017-04-18 Bank Services Agreement with Synapse Financial Technologies"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2019-esop","record":{"id":"e-2019-esop","date":"2019-08","title":"Labor Department announces a court order requiring the bank and a former CEO to restore $6.5 million to an ESOP","claim_ids":["c-enf-esop"]},"reading":"2019-08 Labor Department announces a court order requiring the bank and a former CEO to restore $6.5 million to an ESOP"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2020-hill","record":{"id":"e-2020-hill","date":"2020-05-26","title":"Federal Reserve prohibition orders against two former employees","claim_ids":["c-enf-hill"]},"reading":"2020-05-26 Federal Reserve prohibition orders against two former employees"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2020-dave","record":{"id":"e-2020-dave","date":"2020-07-13","title":"Bank Services Agreement with Dave","claim_ids":["c-baas-dave-agreement"]},"reading":"2020-07-13 Bank Services Agreement with Dave"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2022-flood","record":{"id":"e-2022-flood","date":"2022-06-15","title":"Federal Reserve flood-insurance civil money penalty of $13,950","claim_ids":["c-enf-flood"]},"reading":"2022-06-15 Federal Reserve flood-insurance civil money penalty of $13,950"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2022-doj","record":{"id":"e-2022-doj","date":"2022-10-17","title":"Court enters a consent order in the Justice Department mortgage-pricing case","claim_ids":["c-enf-doj-2022"]},"reading":"2022-10-17 Court enters a consent order in the Justice Department mortgage-pricing case"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2023-break","record":{"id":"e-2023-break","date":"2023-09-25","title":"Evolve notifies Synapse that it is in breach of contract","claim_ids":["c-syn-sept-2023"]},"reading":"2023-09-25 Evolve notifies Synapse that it is in breach of contract"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2023-migration","record":{"id":"e-2023-migration","date":"2023-10-05","title":"A large fintech tells its users that their funds will move to Synapse Brokerage","claim_ids":["c-syn-migration"]},"reading":"2023-10-05 A large fintech tells its users that their funds will move to Synapse Brokerage"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-bankruptcy","record":{"id":"e-2024-bankruptcy","date":"2024-04-22","title":"Synapse files for Chapter 11 bankruptcy","claim_ids":["c-syn-bankruptcy","c-syn-deficit-known"]},"reading":"2024-04-22 Synapse files for Chapter 11 bankruptcy"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-freeze","record":{"id":"e-2024-freeze","date":"2024-05-11","title":"Evolve freezes activity for all Synapse end users","claim_ids":["c-syn-freeze"]},"reading":"2024-05-11 Evolve freezes activity for all Synapse end users"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-breach","record":{"id":"e-2024-breach","date":"2024-05-29","title":"Evolve discovers a ransomware attack later reported to affect 7.6 million people","claim_ids":["c-brc-maine","c-brc-attack"]},"reading":"2024-05-29 Evolve discovers a ransomware attack later reported to affect 7.6 million people"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-order","record":{"id":"e-2024-order","date":"2024-06-11","title":"Federal Reserve and Arkansas cease-and-desist order takes effect","claim_ids":["c-reg-order"]},"reading":"2024-06-11 Federal Reserve and Arkansas cease-and-desist order takes effect"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-senators","record":{"id":"e-2024-senators","date":"2024-06-28","title":"Senators write to Evolve and others about frozen Synapse funds","claim_ids":["c-reg-senators-2024"]},"reading":"2024-06-28 Senators write to Evolve and others about frozen Synapse funds"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-yotta","record":{"id":"e-2024-yotta","date":"2024-09-13","title":"Yotta sues Evolve Bancorp and Evolve Bank & Trust","claim_ids":["c-lit-yotta-filed"]},"reading":"2024-09-13 Yotta sues Evolve Bancorp and Evolve Bank & Trust"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-mdl","record":{"id":"e-2024-mdl","date":"2024-10-04","title":"Data-breach cases are consolidated as MDL No. 3127","claim_ids":["c-brc-mdl"]},"reading":"2024-10-04 Data-breach cases are consolidated as MDL No. 3127"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-reconciliation","record":{"id":"e-2024-reconciliation","date":"2024-10-18","title":"Ankura's reconciliation for Evolve is completed","claim_ids":["c-rec-ankura"]},"reading":"2024-10-18 Ankura's reconciliation for Evolve is completed"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2024-trustee","record":{"id":"e-2024-trustee","date":"2024-11-12","title":"Synapse trustee's twelfth status report on distributions by partner banks","claim_ids":["c-rec-trustee-fbo"]},"reading":"2024-11-12 Synapse trustee's twelfth status report on distributions by partner banks"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-president","record":{"id":"e-2025-president","date":"2025-02","title":"Mark Mosteller becomes president as Scott Stafford steps away (reported)","claim_ids":["c-brd-feb-2025-memo"]},"reading":"2025-02 Mark Mosteller becomes president as Scott Stafford steps away (reported)"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-bowman-letter","record":{"id":"e-2025-bowman-letter","date":"2025-04-22","title":"Senators' letter to Governor Bowman on the Federal Reserve's supervision of Evolve","claim_ids":["c-reg-senators-2025"]},"reading":"2025-04-22 Senators' letter to Governor Bowman on the Federal Reserve's supervision of Evolve"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-ceo","record":{"id":"e-2025-ceo","date":"2025-08-13","title":"Robert Hartheimer is named chief executive","claim_ids":["c-brd-hartheimer-appointed"]},"reading":"2025-08-13 Robert Hartheimer is named chief executive"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-finra","record":{"id":"e-2025-finra","date":"2025-08-28","title":"FINRA files a complaint against two former Synapse Brokerage officers","claim_ids":["c-lit-finra-complaint"]},"reading":"2025-08-28 FINRA files a complaint against two former Synapse Brokerage officers"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-cfpb-judgment","record":{"id":"e-2025-cfpb-judgment","date":"2025-09-12","title":"Stipulated final judgment in the CFPB case against Synapse","claim_ids":["c-rec-cfpb-judgment"]},"reading":"2025-09-12 Stipulated final judgment in the CFPB case against Synapse"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-arrest","record":{"id":"e-2025-arrest","date":"2025-10-23","title":"Hartheimer is arrested and then dismissed by the bank","claim_ids":["c-ceo-arrest","c-ceo-dismissal"]},"reading":"2025-10-23 Hartheimer is arrested and then dismissed by the bank"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2025-cfpb-fund","record":{"id":"e-2025-cfpb-fund","date":"2025-11-28","title":"CFPB allocates $46,248,291 from its Civil Penalty Fund to Synapse victims","claim_ids":["c-rec-cfpb-fund"]},"reading":"2025-11-28 CFPB allocates $46,248,291 from its Civil Penalty Fund to Synapse victims"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-plea","record":{"id":"e-2026-plea","date":"2026-01-05","title":"Hartheimer pleads guilty to a two-count federal information","claim_ids":["c-ceo-plea"]},"reading":"2026-01-05 Hartheimer pleads guilty to a two-count federal information"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-distributions","record":{"id":"e-2026-distributions","date":"2026-01-08","title":"Evolve announces further distributions to certain Synapse end users","claim_ids":["c-rec-2026-statement"]},"reading":"2026-01-08 Evolve announces further distributions to certain Synapse end users"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-yotta-dismissed","record":{"id":"e-2026-yotta-dismissed","date":"2026-02-18","title":"Court dismisses Yotta's amended complaint; Yotta appeals","claim_ids":["c-lit-yotta-claims"]},"reading":"2026-02-18 Court dismisses Yotta's amended complaint; Yotta appeals"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-coastal","record":{"id":"e-2026-coastal","date":"2026-04-29","title":"Coastal Community Bank signs a non-binding term sheet to buy BaaS programme assets and deposits","claim_ids":["c-baas-coastal"]},"reading":"2026-04-29 Coastal Community Bank signs a non-binding term sheet to buy BaaS programme assets and deposits"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-dfpi","record":{"id":"e-2026-dfpi","date":"2026-05-15","title":"California regulator's consent order with Yotta","claim_ids":["c-lit-dfpi-yotta"]},"reading":"2026-05-15 California regulator's consent order with Yotta"}
{"case_id":"evolve-bank-trust","version":"1.0","as_of":"2026-10-16","record_type":"events","id":"e-2026-sentence","record":{"id":"e-2026-sentence","date":"2026-06-04","title":"Hartheimer is sentenced to 51 months in prison","claim_ids":["c-ceo-sentence"]},"reading":"2026-06-04 Hartheimer is sentenced to 51 months in prison"}