--- title: "Evolve's Open Banking business: fintech partners and accounts" language: en canonical: https://dossiertwist.com/dossiers/evolve-bank-trust/open-banking/ 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's Open Banking business: fintech partners and accounts **Question.** How does Evolve's Open Banking business work, and which fintech companies has it served? **Answer.** Since 2017 the bank's Open Banking division has let fintech companies offer accounts, cards and payments built on Evolve: the fintech keeps the customer relationship while the bank holds the money, often in pooled for-benefit-of accounts or sub-deposit accounts placed at other banks. Partners named in filings and the bank's own materials include Affirm, Dave, Branch, Marqeta, Stripe, Mercury, Melio, EarnIn, Airwallex, B9 and Step. In 2025 Mercury announced its exit and Dave began opening new members at another bank, and in 2026 a plan to sell some programmes to Coastal Community Bank was dropped. ## How the model works - 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. [src-012] [src-004] [src-003] [src-005] [src-020] [src-031] - 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. [src-045] [src-085] [src-061] [src-073] ## Partners - 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. [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] - 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. [src-020] [src-005] [src-043] [src-114] - Documented: 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. [src-020] - Qualification: Logo text recognised from an image; the kit does not describe the services provided to each. - Documented: The corresponding page of the 2024 kit shows the logos of Affirm, Airwallex, Bond, Branch, Dave, Marqeta and Melio. [src-005] - Qualification: Logo text recognised from an image. ## Departures and a dropped sale - 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. [src-035] [src-050] [src-096] [src-041] - 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. [src-035] [src-050] [src-096] - 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. - 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. [src-028] [src-119] ## Disputes involving partners - 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. [src-041] [src-094] [src-067] [src-031] - Documented: 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. [src-067] - Qualification: Allegations in the CFPB's complaint. - 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. [src-031] - Qualification: The senators' characterisation; the CFPB case against SoLo Funds is not in the retained record. ## Sources - [src-012] Company statement source · src-012 - [src-004] Other source · src-004 - [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-005] Company statement source · src-005 - [src-020] Company statement source · src-020 - [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-045] Company statement source · src-045 - [src-085] Company statement source · src-085 - [src-061] Company statement source · src-061 - [src-073] Company statement source · src-073 - [src-041] Dave Inc. Form 10-K for the year ended December 31, 2025, U.S. Securities and Exchange Commission (EDGAR), 2026-03 - [src-042] Affirm Holdings, Inc. Form 10-K for the fiscal year ended June 30, 2025, U.S. Securities and Exchange Commission (EDGAR), 2025-08 - [src-034] Company statement source · src-034 - [src-046] Company statement source · src-046 - [src-051] Marqeta, Inc. Form 10-K for the year ended December 31, 2025, U.S. Securities and Exchange Commission (EDGAR), 2026-02 - [src-076] Company statement source · src-076 - [src-092] Licensee record: Stripe Payments Company, California Department of Financial Protection and Innovation, 2026-10-16 - [src-091] Licensee record: Airwallex US, LLC, California Department of Financial Protection and Innovation, 2026-10-16 - [src-071] Company statement source · src-071 - [src-090] Branch Messenger, Inc. Form D notice, U.S. Securities and Exchange Commission (EDGAR), 2021 - [src-067] CFPB complaint against Walmart Inc. and Branch Messenger, Inc. (D. Minn. No. 24-cv-4610), Consumer Financial Protection Bureau, 2024-12-23 - [src-074] Company statement source · src-074 - [src-049] Usio, Inc. Form 10-K for the year ended December 31, 2025, U.S. Securities and Exchange Commission (EDGAR), 2026-03 - [src-043] Company statement source · src-043 - [src-114] Company statement source · src-114 - [src-035] Media source · src-035 - [src-050] Other source · src-050 - [src-096] Media source · src-096 - [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 - [src-094] Court record source · src-094