Evidence records

documentedIn 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. ¹

documentedThe 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. ¹

documentedThe 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. ^{1 2}

documentedThe 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. ³

documentedAlthough 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. ^{4 5}

documentedEvolve 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. ⁶

documentedThe 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. ^{7 8}

qualification

These are third-party screening tags derived from published enforcement releases, not a fresh sanctions screening.

documentedThe FDIC record names EVOLVE BCORP INC (Evolve Bancorp, Inc.), RSSD 1142411 of West Memphis, Arkansas, as the bank's regulatory holding company. ¹

documentedThe 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. ²

documentedOn 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. ³

documentedThe 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. ⁴

documentedIn 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. ⁵

documentedIn 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. ⁶

documentedIn 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. ⁷

documentedEvolve 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. ⁸

documentedThe 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. ⁹

documentedIn 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. ¹⁰

documentedThe 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. ¹

documentedThe 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. ²

documentedThe 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. ^{3 4}

documentedThe 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. ⁵

documentedThe 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). ⁵

documentedThe 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). ⁶

documentedOn 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. ⁷

documentedSeveral 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. ^{8 9 10 11}

documentedForrest 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. ^{12 2}

documentedJohn 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. ^{6 2 5}

documentedThe 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. ¹³

documentedThe 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. ¹⁴

documentedOn 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. ^{15 16}

documentedOn 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. ¹⁷

documentedAfter 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. ^{18 19}

documentedThe 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. ²⁰

qualification

This describes one retrieved page; it does not exclude an appointment announced elsewhere.

documentedIn 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. ^{21 15}

documentedAccording 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. ⁵

documentedDonald 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. ^{8 5}

documentedLewis 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. ^{11 5}

documentedRaymond 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. ^{22 23}

documentedAl 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. ^{10 24}

documentedLon 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. ²⁵

documentedJohn 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. ^{9 5}

documentedAccording 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. ⁵

documentedMark 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. ⁵

documentedMonica 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. ²⁶

documentedUnder 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. ¹³

documentedBefore 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. ^{1 2}

documentedRepay 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). ²

documentedThe 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. ^{3 4}

documentedIn 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. ⁵

documentedOn 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. ⁵

qualification

The retained docket does not describe the specific statutes of conviction or the grounds of the government's appeal.

documentedAccording 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. ^{1 2}

documentedEffective 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. ¹

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.

documentedThe 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). ¹

qualification

The order also records that the companies had begun remedial action.

documentedThe 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. ¹

documentedThe 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. ¹

documentedWith 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. ¹

documentedThe 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. ^{2 3}

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.

documentedThe 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. ¹

documentedDave 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. ^{2 3}

qualification

Plaintiffs' allegations; no ruling on the merits.

documentedEvolve 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. ^{4 5}

documentedThe 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. ^{6 7}

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.

documentedEvolve'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. ^{8 9}

documentedUnder 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. ¹⁰

documentedMelio'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. ¹¹

documentedDave 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. ²

documentedDave'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. ²

documentedAffirm 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. ¹²

documentedEvolve 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. ^{13 14 15}

documentedStripe'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. ^{16 17 18}

documentedAirwallex'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. ¹⁹

documentedEarnIn'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. ²⁰

documentedBranch 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. ^{21 22}

documentedThe 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. ²³

documentedDwolla 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. ⁹

documentedThe 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. ²⁴

qualification

The bank's own list; it does not distinguish card networks, programme managers and fintech programmes.

documentedThe bank's news page, in its retained copy, lists an item titled 'Coinstar Expands Transfer to Account Service with TabaPay and Evolve Bank & Trust'. ²⁵

documentedOn 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. ^{26 27}

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.

documentedThe 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. ²⁸

documentedEffective 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. ^{1 2}

documentedEffective 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. ^{3 4}

qualification

The Hills consented to the orders without admitting or denying the Board's allegations, and before any adjudication.

documentedOn 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. ⁵

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.

documentedOn 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. ^{6 7}

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.

documentedIn 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. ^{8 9}

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.

documentedSynapse 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. ^{1 2}

documentedAccording 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. ¹

documentedEvolve 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. ^{1 2}

documentedOn 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'. ^{3 4}

documentedIn 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. ²

documentedThe 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. ²

documentedAccording 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. ²

documentedThe 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. ²

documentedThe 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. ^{2 1}

qualification

Neither estimate attributes the shortfall to a particular bank.

documentedThe 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. ¹

documentedThe 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. ^{6 1}

documentedIn 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. ^{7 8}

documentedOn 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. ¹

documentedIn 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. ¹

documentedIn 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'. ²

documentedA 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. ⁵

documentedOn 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. ^{6 7 8}

documentedMark 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. ⁷

documentedJeffrey 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. ⁹

documentedOn 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. ^{11 12}

qualification

The order concerns Yotta's conduct; Evolve is not a party to it.

documentedAccording 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. ¹

documentedThe 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. ¹

documentedEvolve'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. ^{2 3}

qualification

The retained copy is an archived web copy of the state's breach-notice listing.

documentedPartner 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. ^{4 5 6 7}

documentedAfter 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. ^{8 9}

qualification

Allegations of the plaintiffs; the court has made no finding of liability.

documentedFDIC 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. ^{1 2}

qualification

Bank-only figures from the FDIC; they exclude the holding company.

documentedAt 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. ¹

documentedThe 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. ³

documentedThe 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. ^{4 5}

documentedEvolve 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. ⁶

documentedA 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. ⁷