--- title: "Evolve Bank & Trust: fintech partner bank, Synapse and regulators" language: en canonical: https://dossiertwist.com/dossiers/evolve-bank-trust/ as_of: 2026-10-16 keywords: ["Evolve Bank & Trust","Evolve Bancorp","Synapse Financial Technologies","Synapse Brokerage","Banking-as-a-Service","Open Banking","cease-and-desist order","Federal Reserve","Arkansas State Bank Department","FBO accounts","Yotta Technologies","Lineage Bank","AMG National Trust","Scot Lenoir","Robert Hartheimer","data breach","MDL 3127","Ankura reconciliation","CFPB","Coastal Community Bank"] --- # Evolve Bank & Trust: fintech partner bank, Synapse and regulators **Question.** What is Evolve Bank & Trust, who runs it, and what happened to it and to customers' money after the Synapse collapse? **Answer.** Evolve Bank & Trust is an Arkansas-chartered, FDIC-insured bank (Certificate No. 1299) whose executives work from Memphis. Founded in 1925 as First State Bank, it took its present name in 2005, when Evolve Financial Group, organised by Scot Lenoir, acquired its holding company, and from 2017 its Open Banking division served fintech companies. Synapse Financial Technologies sat between the bank and many of those apps and kept the customer ledgers; after Synapse filed for bankruptcy in April 2024 the bank froze end-user funds, and a shortfall estimated at $65 million to $95 million across Synapse's partner banks remains disputed. In June 2024 the Federal Reserve and the Arkansas State Bank Department imposed a cease-and-desist order on the bank and its holding company, Evolve Bancorp; the same year a ransomware attack exposed data of about 7.6 million people. The bank faces class actions over the Synapse funds, lost money in 2025, and its chief executive appointed in August 2025 was dismissed after his arrest that October. ## What this research adds - 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. [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] ## The bank - 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. [src-001] [src-005] [src-024] - 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. [src-003] [src-007] [src-101] [src-009] [src-001] [src-010] ## Owners and leadership - 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. [src-033] [src-025] [src-001] [src-002] [src-017] [src-018] [src-039] [src-108] [src-024] [src-004] [src-008] - Documented: 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'. [src-024] - 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. - 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. [src-008] [src-054] [src-004] [src-014] [src-006] [src-072] [src-097] [src-114] - 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. [src-006] [src-004] [src-072] [src-014] - 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. ## The Open Banking business - 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. [src-012] [src-004] [src-003] [src-031] [src-035] [src-050] [src-096] ## Synapse and the frozen funds - 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. [src-029] [src-052] [src-027] [src-004] - 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. [src-030] [src-029] [src-037] [src-035] ## Orders, suits and the data breach - 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. [src-003] [src-079] [src-080] [src-104] [src-113] - 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. [src-044] [src-082] [src-081] [src-083] [src-084] [src-077] [src-115] - Documented: 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. [src-077] [src-084] [src-115] - 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. ## Finances - 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. [src-117] [src-118] [src-001] [src-035] [src-003] [src-028] [src-119] - 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. [src-035] [src-003] - 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. - 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. ## Sources - [src-001] FDIC BankFind institution record for Evolve Bank & Trust (Cert. 1299), Federal Deposit Insurance Corporation, 2026-10-16 - [src-005] Company statement source · src-005 - [src-024] Report of the Bank Commissioner of the State of Arkansas 2025, Arkansas State Bank Department (Bank Commissioner), 2025-10 - [src-003] Order to cease and desist issued upon consent: Evolve Bancorp, Inc. and Evolve Bank & Trust, Board of Governors of the Federal Reserve System, 2024-06-11 - [src-007] Company statement source · src-007 - [src-101] Evolve Bank & Trust 2022 annual report (Business ID 956221), Mississippi Secretary of State, 2022-04-10 - [src-009] Other source · src-009 - [src-010] Other source · src-010 - [src-033] Media source · src-033 - [src-025] Report of the Bank Commissioner of Arkansas 2006, Arkansas Bank Commissioner (FRASER archive, Federal Reserve Bank of St. Louis), 2006 - [src-002] Request for Evolve Bancorp FR Y-6 annual report, December 31, 2025, Federal Financial Institutions Examination Council, National Information Center, 2026-10-16 - [src-017] Request for Evolve Bancorp FR Y-6 annual report, December 31, 2024, Federal Financial Institutions Examination Council, National Information Center, 2026-10-16 - [src-018] Evolve Bancorp FR Y-9SP parent company only report form, December 31, 2025, Federal Financial Institutions Examination Council, National Information Center, 2026-10-16 - [src-039] Report of the Bank Commissioner of the State of Arkansas 2024, Arkansas State Bank Department (Bank Commissioner), 2025-07 - [src-108] Report of the Bank Commissioner of the State of Arkansas 2023, Arkansas State Bank Department (Bank Commissioner), 2025-07 - [src-004] Other source · src-004 - [src-008] Company statement source · src-008 - [src-054] Repay Holdings Corporation definitive proxy statement (2021), U.S. Securities and Exchange Commission (EDGAR), 2021 - [src-014] Media source · src-014 - [src-006] Media source · src-006 - [src-072] Court record source · src-072 - [src-097] Company statement source · src-097 - [src-114] Company statement source · src-114 - [src-012] Company statement source · src-012 - [src-031] Letter from Senators Warren, Baldwin, Wyden and Fetterman to Governor Bowman about Evolve, U.S. Senate Committee on Banking, Housing, and Urban Affairs, 2025-04-22 - [src-035] Media source · src-035 - [src-050] Other source · src-050 - [src-096] Media source · src-096 - [src-029] CFPB complaint against Synapse Financial Technologies, Inc. (Adv. No. 1:25-ap-01052), Consumer Financial Protection Bureau, 2025-08-21 - [src-052] Consent order: Yotta Technologies, Inc., California Department of Financial Protection and Innovation, 2026-05-15 - [src-027] Regulatory record source · src-027 - [src-030] Court record source · src-030 - [src-037] Notice to California Yotta customers, California Department of Financial Protection and Innovation, 2026-05 - [src-079] Press releases 2026, Board of Governors of the Federal Reserve System, 2026-10-16 - [src-080] Press releases 2025, Board of Governors of the Federal Reserve System, 2025-12 - [src-104] Media source · src-104 - [src-113] Court record source · src-113 - [src-044] Company statement source · src-044 - [src-082] Regulatory record source · src-082 - [src-081] Media source · src-081 - [src-083] In re: Evolve Bank & Trust Customer Data Security Breach Litigation (W.D. Tenn. No. 2:24-md-03127), U.S. Government Publishing Office (USCOURTS), 2026-10-16 - [src-084] Order in MDL No. 3127 (Doc. 93), U.S. Government Publishing Office (USCOURTS), 2025-11-13 - [src-077] Court record source · src-077 - [src-115] Media source · src-115 - [src-117] FDIC financial data for Evolve Bank & Trust, December 31, 2025, Federal Deposit Insurance Corporation, 2026-10-16 - [src-118] FDIC financial data for Evolve Bank & Trust, 2019 to 2024, Federal Deposit Insurance Corporation, 2026-10-16 - [src-028] Coastal Financial Corporation Form 8-K (April 29, 2026), U.S. Securities and Exchange Commission (EDGAR), 2026-04-29 - [src-119] Media source · src-119