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Synapse Financial Technologies: the collapse of a banking-as-a-service provider

Evidence records

Full assertions with source references, qualifications, responses and known outcomes. The topic articles explain these records in context.

published
17 oct 2026
records as of
15 oct 2026
entities
61
sources
103
cite entities.csv

the questionWhich records support the articles?

1Synapse Financial Technologies: company records and group structure

documentedSynapse Financial Technologies, Inc. is a Delaware corporation. Its Chapter 11 docket gives employer identification number 46-5396710 and an address at 21255 Burbank Boulevard, Suite 120, Woodland Hills, California; the U.S. Consumer Financial Protection Bureau (CFPB) describes Woodland Hills as its principal place of business. 1 2

documentedA 2021 civil complaint filed by the landlord of Synapse's former San Francisco office describes Synapse Financial Technologies, Inc. as a Delaware corporation registered with the California Secretary of State as a foreign stock corporation, doing business as SynapseFi, SynapsePay, Synapse Investment Advisors, LLC and TN Synabot Advisors LLC. 3

qualification
The plaintiff's description in a pleading; the California registration and the trade names are not confirmed by a retained registry record.

documentedAccording to the company's first-day bankruptcy filing of April 22, 2024, Sankaet Pathak founded the business in 2014 as Synapse Payments LLC, and it changed its name to Synapse Financial Technologies, Inc. in 2016 when it converted to a corporation. A consent order of the New Hampshire Banking Department (No. 16-041) likewise refers to Synapse Payments LLC as now known as Synapse Financial Technologies, Inc., doing business as SynapseFi. 4 5

documentedSEC EDGAR lists Synapse Payments, LLC under Central Index Key 0001638446 as a Tennessee entity with business and mailing addresses at 6745 Lenox Center Ct., Suite 300, Memphis. Its only filing is a Form D notice of an exempt offering of securities filed on April 1, 2015. 6

documentedThe 2015 Form D describes Synapse Payments, LLC as a Tennessee limited liability company organised in 2014 and lists four related persons: Sankaet Pathak, marked as executive officer, director and promoter and described as president and member of the member-managed LLC, and Bryan Keltner, Jeffrey Webb and Douglas Marchant, each marked as a director and described as a member. It reports $700,000 of equity sold to ten investors, two of them not accredited, with the first sale on March 16, 2015. 7

documentedIn its bankruptcy filings the company described itself as a non-bank technology company whose software allowed financial technology platforms (fintechs) to offer the products of partner banks and other financial institutions to their own customers, called end users; it called itself one of the first, if not the first, to pioneer a banking-as-a-service (BaaS) platform. The same filing stated that end users were customers of the fintechs and the partner institutions, not of the debtor, and that the debtor was not in the flow of funds and did not receive funds from end users. 8 4

documentedAccording to the debtor, as of January 2024 it had service contracts with more than 20 partner financial institutions, directly or indirectly for sweep networks, and with 100 fintechs, and about 10 million end users used its platform; at the petition date it engaged about 89 employees and contractors in the United States and about 19 people abroad through a third-party employer service. 4

documentedAnnouncing its Series A financing in September 2018, the company (then styled SynapseFI) stated that since its founding in 2014 it had processed more than $10 billion in transactions for more than 1.5 million end users and provided white-labelled services as APIs to more than 100 startups and financial services firms, including payment processing, deposit accounts, debit and credit card issuance, custodial accounts and crypto wallets. 9

documentedWashington's business registry recorded Synapse Financial Technologies, Inc. under UBI 604698641 as a foreign profit corporation of Delaware, with the date January 15, 2021 in its incorporation-date field, an address at 101 2nd St, Suite 1500, San Francisco, National Registered Agents, Inc. as registered agent and a contact address on the synapsefi.com domain; its officers were listed as Michael Rasic and Sankaet Pathak, without titles. The last annual report was filed on January 11, 2023, and a statement of termination was filed on May 3, 2024. 10 11

documentedA corporate-data aggregator lists the Delaware corporation as company number 6083706, with National Registered Agents, Inc. as agent in Dover, and shows foreign-registration branches of that company in Utah, Arizona, Washington (604698641), Illinois and Tennessee (000858713). The Washington and Tennessee registrations carry Synapse's San Francisco address. 12 13

documentedTennessee's record of the foreign registration (000858713), shown as a branch of Delaware company 6083706, has the status Inactive Revoked (Administrative); its most recent filing listed is the 2022 annual report, filed on May 1, 2023. 13

documentedIn April 2024 the debtor stated in court that it wholly owned two subsidiaries, Synapse Credit LLC and Synapse Brokerage LLC, and that Synapse Brokerage was a registered broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA). 8

documentedSynapse Brokerage LLC was formed in Delaware on January 15, 2004 and had been registered with FINRA since March 2006 under earlier names: FINRA refers to it as formerly known as MVP Global Trading, LLC, and its BrokerCheck report lists the other name MVP Financial, used in California, Florida and New York. According to FINRA, Synapse Financial Technologies acquired the firm in July 2020 and the firm conducted no business after the acquisition until September 2023. BrokerCheck identifies the firm by CRD number 137662 and SEC file number 8-67105. 14 15

documentedBefore Synapse acquired it, the firm, then MVP Financial, LLC, had its FINRA membership suspended on April 10, 2017 after failing to file its 2016 annual audit report; the suspension was lifted on May 8, 2017. 14

documentedSynapse Brokerage's BrokerCheck report reproduces Form BD ownership schedules that list Synapse Financial Technologies Inc. as a domestic entity holding the position of equity owner with 75% or more since June 2020, and list Sankaet Pathak as an indirect owner holding 25% but less than 50% through Synapse Financial Technologies Inc., with his relationship to that direct owner given as chief executive officer, established December 2019. 14

qualification
The schedules give ownership bands, not exact percentages, and the report does not date Pathak's holding beyond the stated relationship date.

documentedBrokerCheck and the California Department of Financial Protection and Innovation (DFPI) give Synapse Brokerage's principal office as 10233 South Parker Road, Suite 300, Office 313, Parker, Colorado; DFPI describes the firm as a Delaware limited liability company and a subsidiary of Synapse Financial Technologies, Inc. 14 16

documentedSynapse Credit LLC, doing business as Synapse (NMLS 1971454), is a Delaware limited liability company whose main office was at 101 Second Street, Suite 1500, San Francisco; the Connecticut Department of Banking had licensed it as a small loan lender since September 15, 2020. Washington registered it as a foreign limited liability company (UBI 604595480) on March 26, 2020, with Corporation Service Company as agent and Sankaet Pathak and Michael Rasic as officers; that registration was terminated by a statement filed on December 3, 2024. 17 18 10 19

documentedAccording to the debtor, it established Synapse Credit around 2019 to hold state lending licences and offer loans to the end users of fintechs it worked with; the loans were typically secured by restricted cash or reserves for their full amount. Synapse Credit had no employees, and its arrangement with the debtor was set out in an Intercompany Service and Expense Sharing Agreement. 4

documentedThe Chapter 11 trustee reported that from 2014 Synapse opened demand deposit accounts (DDAs) at certain banks on behalf of about 100 fintech platforms and their end users; that from 2020 it developed a cash management program with its subsidiary Synapse Brokerage LLC, opening cash management accounts at banks for fintech platforms and their end users; and that it offered secured loans to the platforms' end users through its subsidiary Synapse Credit LLC. 20

documentedThe trustee also reported, citing Pathak's sworn testimony at the creditors' meeting, that Synapse Brokerage, a fully owned subsidiary founded to establish cash management and money market account programs, had not established those programs and had deployed only a sweep network at American Deposit Management Company (ADMC), used to enlarge the FDIC insurance coverage available to depositors and to earn interest that was distributed among Synapse, the fintech platforms and end users under their agreements. 20 21

documentedSynapse Money LLC, a Delaware limited liability company, was registered in Washington as a foreign LLC (UBI 604516460) on November 14, 2019 at 101 2nd St, Suite 1500, San Francisco, the address then also recorded for Synapse and Synapse Credit, with Corporation Service Company as agent; the registration was withdrawn on January 5, 2021. The record names no officers or owner. 22 18 23

qualification
The shared address and name are the only documented link to Synapse; no retained record establishes who owned Synapse Money LLC.

sources in this section

  1. Court record source · src-001 identified by category only · Court record
  2. Enforcement action page: Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 15 Sep 2025
  3. Court record source · src-064 identified by category only · Court record
  4. Court record source · src-023 identified by category only · Court record
  5. Document register entry: Synapse Payments LLC, 16-041, Consent Order New Hampshire Banking Department · 19 Jun 2020
  6. EDGAR company search result: Synapse Payments, LLC (CIK 0001638446) U.S. Securities and Exchange Commission (EDGAR)
  7. Form D notice of exempt offering: Synapse Payments, LLC U.S. Securities and Exchange Commission (EDGAR) · 1 Apr 2015
  8. Court record source · src-003 identified by category only · Court record
  9. Company statement source · src-071 identified by category only · Company statement
  10. Corporate registry source · src-005 identified by category only · Corporate registry
  11. Corporate registry source · src-058 identified by category only · Corporate registry
  12. Corporate registry source · src-006 identified by category only · Corporate registry
  13. Corporate registry source · src-013 identified by category only · Corporate registry
  14. BrokerCheck report: Synapse Brokerage LLC (CRD 137662) Financial Industry Regulatory Authority (FINRA)
  15. Regulatory record source · src-009 identified by category only · Regulatory record
  16. Order revoking Synapse Brokerage LLC's broker-dealer certificate California Department of Financial Protection and Innovation · 22 Jan 2025
  17. Notice of intent to refuse to renew small loan license and notice of right to hearing: Synapse Credit LLC Connecticut Department of Banking · 26 Sep 2022
  18. Corporate registry source · src-011 identified by category only · Corporate registry
  19. Corporate registry source · src-091 identified by category only · Corporate registry
  20. Court record source · src-017 identified by category only · Court record
  21. Court record source · src-032 identified by category only · Court record
  22. Corporate registry source · src-018 identified by category only · Corporate registry
  23. Corporate registry source · src-059 identified by category only · Corporate registry

2How Synapse worked: partner banks, pooled accounts and fintech clients

attributedThe CFPB describes Synapse's technology as a bridge between non-bank fintech platforms that dealt with consumers and the banks that held consumers' money, issued debit cards and processed ACH and wire transfers. According to the complaint, Synapse's software communicated the transactions that end users requested through the fintech platforms to the partner banks to perform, and Synapse was responsible for tracking and maintaining records of the movement of consumers' funds across these banks and for ensuring that those records matched the banks' own records. 1 2 3

qualification
Allegations in the CFPB's complaint of August 21, 2025. In the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied them, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

attributedFINRA found that Synapse partnered with two deposit banks, from around 2017 and 2022 respectively, and that end users who opened deposit accounts through fintechs entered into account agreements with one of those banks and deposited funds directly with it. Before December 2023 end-user funds at the first bank were held in omnibus accounts in that 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 to track individual balances. By September 2023, FINRA found, fintechs with millions of end users had more than $2 billion of end-user funds in deposit accounts at the two banks. 4

qualification
Findings in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that they are not binding on any other person or entity named as a respondent in this or any other proceeding. The order refers to the banks only as DDA Bank 1 and DDA Bank 2.

documentedThe Chapter 11 trustee reported that Synapse often used several partner banks for different functions of the same fintech partner, so that an end user's deposits might be held at one bank while withdrawals through the same platform were processed from an account at another bank; the trustee said this model made it both essential and difficult to reconcile transactions and to ensure that each end user received the correct amount. The trustee defined an FBO account as a pooled custodial account that lets a company manage funds for the benefit of its users without owning the account. 5

documentedSynapse's master services agreement with a platform client, filed with the SEC in 2018 as an exhibit to the client's Form 8-K and signed by Sankaet Pathak as Founder & CEO on October 23, 2018, states that all bank services are provided to the platform directly by Evolve Bank & Trust or a successor institution designated by Synapse; that Synapse's APIs let the platform communicate its requests to the bank while Synapse helps the platform and the bank manage risk and compliance; and that the platform authorises Synapse to act on its behalf in transmitting financial information and requests. The agreement defines sub-accounts within an FBO deposit account held in the platform's name for the benefit of its users. 6

documentedAccording to the CFPB, Synapse signed a Bank Services Agreement with Evolve Bank & Trust on or about April 18, 2017 and a Master Bank Services Agreement on or about September 23, 2022; in 2017 Evolve was Synapse's only partner bank, and at least until the summer of 2023 Synapse gave consumers who opened accounts through fintech platforms a deposit account agreement on Evolve's behalf. 2

documentedA 2024 trade-press report identifies the first version of a Synapse/Evolve deposit agreement as dated September 7, 2017, and a 2025 business-press report states that Synapse and Evolve began working together in 2017, when Synapse's deposits had grown into the millions of dollars and it was looking for more banking partners. 7 8

attributedA 2024 trade-press report, citing former employees, states that Jeff Webb and Doug Marchant, whose $700,000 provided Synapse's initial investment, helped introduce Synapse to its first two bank partners, Triumph Bank and Independent Bank. 7

qualification
Reported account based on unnamed former employees; no agreement with either bank is retained in the record.

documentedThe trustee reported that Synapse's 2021 contract with American Bank, its 2022 contract with Evolve and its 2022 contract with Lineage Bank include clauses stating that Synapse has no right to or interest in funds deposited in an end user's account, and concluded that funds in the end users' DDA and FBO accounts are not property of the bankruptcy estate. At the continued creditors' meeting on June 10, 2024, Pathak and general counsel Tracey Guerin testified under oath that all funds in Synapse-related DDA and FBO accounts at the partner banks belonged to end users; the exception they identified was Synapse's own operating money, deposited before the bankruptcy at Evolve in accounts within Synapse's ecosystem, so that Evolve held Synapse property in an FBO account on behalf of Synapse as an end user. 9

documentedBy the time of the bankruptcy, according to the trustee, most end-user funds were held in omnibus FBO accounts and the rest in DDAs across four partner banks: American Bank, AMG National Trust, Evolve Bank & Trust and Lineage Bank. 9

documentedThe trustee was informed that American Bank held brokered sweep deposits from Synapse Brokerage and issued debit cards for five Synapse fintech partners, without taking part in payment processing or lending; at American Bank's request Synapse and the bank had begun a wind-down plan before the bankruptcy, and by May 17, 2024 the bank held less than $50,000 of sweep deposits. 5

documentedAMG National Trust began accepting brokered sweep deposits from Synapse Brokerage in August 2023, according to the trustee; Synapse Brokerage opened deposit accounts at AMG in its own name and FBO accounts for its fintech partners and their end users, and from February 2024 AMG also processed ACH and wire transactions for four of Synapse Brokerage's fintech partners. AMG held no accounts for Synapse itself and had no official relationship with any fintech partner or end user; Synapse Brokerage was the custodian of record and processed and recorded all end-user transactions. 5

documentedThe trustee was informed that Evolve provided banking services, including DDA accounts, to Synapse Financial Technologies and payment processing services for Synapse Brokerage. 5

documentedLineage Bank provided ACH and wire transfer processing for Synapse as an originating depository financial institution under a master services agreement, according to the trustee. Lineage told the trustee that it never maintained accounts for end users or contracted with them directly, that it had only one account with a fintech platform, and that it was not a program bank or custodian for Synapse Brokerage. The CFPB likewise describes Lineage as mainly an originating bank that processed ACH and wire transfers for cash-management end users on Synapse's instructions. 5 2

documentedThe partner banks told the trustee that the funds they held were FBO funds for the benefit of Synapse or of Synapse Brokerage and its end users: AMG held FBO accounts in Synapse Brokerage's name; Evolve held FBO accounts in Synapse's name, where the DDA funds sat, and in Synapse Brokerage's name; and Lineage held an FBO account designated for the benefit of Synapse Financial Technologies, Inc., most of whose funds belonged to brokerage-program end users. Over several months Synapse Brokerage moved about $650 million from Evolve to AMG and other banks while migrating fintech partners and end users to the brokerage, and continued to direct cash between banks as part of its sweep program. 5

attributedAccording to the CFPB, Synapse began offering a cash management program through fintech platforms in 2023, marketing it as a way to give end users more FDIC deposit insurance through sweeps across several banks. Synapse opened accounts with Synapse Brokerage on end users' behalf and omnibus accounts at partner banks in Synapse Brokerage's name; AMG accepted sweep deposits from August 2023. Evolve was not one of the banks engaged to hold program funds, but from October 2023 Synapse directed the transfer of participating end users' funds from Evolve to Synapse Brokerage and on to other banks, while Evolve continued to sponsor debit cards and to receive ACH deposits sent to its routing number. Some platforms did not join the program, and their end users' funds stayed at Evolve. 2 3

qualification
Allegations in the CFPB's complaint of August 21, 2025. In the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied them, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

attributedThe CFPB alleges that after the cash management program began, Synapse directed the movement of end-user funds between Synapse Brokerage and AMG and the other omnibus banks, Evolve (which still processed debit card transactions and received ACH transfers) and Lineage (which originated ACH and wire transfers), and was responsible for tracking where each end user's funds were across all of them and for giving the banks access to the data. 2 3

qualification
Allegations in the CFPB's complaint of August 21, 2025. In the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied them, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

documentedThe trustee noted that the banks holding Synapse-related funds were supervised by federal banking agencies (Evolve by the Federal Reserve, Lineage by the FDIC, and AMG and American Bank by the Office of the Comptroller of the Currency), that the SEC and FINRA regulate Synapse Brokerage, and that Synapse itself was not directly regulated by the Federal Reserve, the FDIC or the OCC. On June 20, 2024 the trustee wrote to the heads of the Federal Reserve, the FDIC, the OCC, the SEC and FINRA asking them to make consumer-protection resources available to end users. 10

documentedAsked why affected customers could not claim deposit insurance, a bank-regulatory consultant quoted in the trade press in May 2024 explained that the customers' funds were either pooled in shared accounts at Evolve or held in sweep accounts arranged through Synapse Brokerage, that fintechs are not banks and are not insured by the FDIC, and that because none of the partner banks had failed the FDIC could not intervene or pay the affected customers. 11

documentedOn July 1, 2024 the Senate Banking Committee majority announced a letter from Senators Sherrod Brown, Ron Wyden, Tammy Baldwin and John Fetterman to Synapse's major investors and principal bank and fintech partners: former CEO Sankaet Pathak; the investors Andreessen Horowitz, Core Innovation Capital and Trinity Ventures; the banks American Bank, AMG National Trust, Evolve Bank & Trust and Lineage Bank; and the fintechs Copper, Juno, Mercury, Yieldstreet and Yotta. 12

documentedThe trustee reported meeting many of Synapse's fintech partners and their counsel, including Changed Inc., Copper, Gig Wage, Grabr, Gravy, IDT, Juno, Latitud, Mercury, Sunny Day Fund, TClub (d/b/a Abound), Yieldstreet and Yotta. 9

documentedCopper, a fintech for teenagers and families operated by NEXT Financial Inc. of Seattle, described SynapseFi in its terms of use (as updated on January 14, 2021) as its backend software provider and a partner of Evolve Bank & Trust, the two together being Copper's 'Bank Partner', and said that SynapseFi's API and its relationship with Evolve enabled Copper to offer banking services. Copper-branded debit cards were issued by Evolve. 13 11

documentedIn May 2024 Copper abruptly closed its bank deposit accounts and debit card services. In a letter to customers on May 12, 2024, co-founder and chief executive Eddie Behringer said the banking middleware service Copper used was sunsetting its service imminently; Copper later said it was coordinating with AMG National Trust and Synapse to return customers' money, while some customers could not yet access their funds. 11

documentedDave Inc., another fintech, stated in its annual report for 2024 that the Synapse bankruptcy had for a number of months affected the ability of customers of fintechs that used Synapse to access funds placed at Synapse's partner banks, including Evolve, and that Dave itself was not directly affected. 14

sources in this section

  1. Enforcement action page: Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 15 Sep 2025
  2. Complaint, CFPB v. Synapse Financial Technologies, Inc. (Adv. No. 1:25-ap-01052-MB) Consumer Financial Protection Bureau · 21 Aug 2025
  3. Stipulated final judgment and order, CFPB v. Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 12 Sep 2025
  4. Regulatory record source · src-009 identified by category only · Regulatory record
  5. Court record source · src-031 identified by category only · Court record
  6. Master services agreement between Synapse and a platform client, Exhibit 99.1 to a Form 8-K (2018) U.S. Securities and Exchange Commission (EDGAR) · 23 Oct 2018
  7. Media source · src-063 identified by category only · Media
  8. Media source · src-021 identified by category only · Media
  9. Court record source · src-017 identified by category only · Court record
  10. Court record source · src-032 identified by category only · Court record
  11. Media source · src-049 identified by category only · Media
  12. Senate Banking Committee majority release on letters to Synapse owners and partners U.S. Senate Committee on Banking, Housing, and Urban Affairs · 1 Jul 2024
  13. Company statement source · src-052 identified by category only · Company statement
  14. Dave Inc. annual report on Form 10-K for 2024 U.S. Securities and Exchange Commission (EDGAR) · Mar 2025

3Synapse and Evolve Bank & Trust: from partnership to dispute

documentedAccording to a 2025 business-press report, Pathak built the Evolve partnership in part through a rapport with Evolve's chairman, Scot Lenoir; both men attended the University of Memphis, Lenoir three decades before Pathak. 1

attributedEvolve's spokespeople have said the bank planned to leave the relationship well before the collapse: in 2025 a spokesperson told the business press that Evolve had a long-standing plan to move to direct relationships with fintechs, away from aggregators like Synapse, and had told Synapse a year in advance that it would exit, and in June 2024 a spokesman said the bank had been trying to separate itself from Synapse since late 2022 because of ledger problems it had found. Pathak, for his part, said he had heard that Evolve was trying to win Synapse's customers directly so as to cut out Synapse's fees. 2 1

qualification
Statements of the two parties to the dispute; no notice of exit or 2022 correspondence is retained in the record.

attributedIn a public statement of July 12, 2024, Evolve said that its services agreement with Synapse had expired by its terms in September 2023 and was in the final stages of winding down when Synapse filed for bankruptcy; that fintechs using Synapse had to find another banking provider, and some chose to migrate in the fall of 2023 to a program run by Synapse Brokerage; that Evolve transferred end-user balances to that program at Synapse's instruction; and that it temporarily provided payment processing for Synapse Brokerage end users, holding some of their funds, without ever entering a program-bank agreement with Synapse Brokerage. FINRA likewise found that the services agreement of Synapse's first deposit bank expired in September 2023, with some services continuing during a wind-down until May 2024. 3 4

qualification
Evolve's own public account; FINRA's order describes an unnamed 'DDA Bank 1' whose particulars match Evolve. Findings in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations.
outcome
The wind-down had not been completed when Synapse filed for bankruptcy.

attributedAccording to Synapse, its chief executive told Scot Lenoir of Evolve in a call on or about September 15, 2023 that Synapse had found improper debits by Evolve since 2017, exceeding $27 million, from depositor funds in Evolve's FBO accounts, which Evolve had used to pay itself and third parties. A 2025 business-press report describes the September 2023 notice as reporting discrepancies of about $13 million in accounts holding customer funds at Evolve and alleging that Evolve paid itself fees, including some it was not entitled to, from customer funds. 5 1

qualification
Synapse's account in a court filing of May 23, 2024 (Doc 178), supported by declarations of Pathak and Guerin; Evolve disputes it. The two published figures ($27 million since 2017 and about $13 million) are not reconciled in the record.
response
Evolve's spokesperson said any accounting errors were Synapse's responsibility: 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.

documentedOn September 25, 2023 Evolve sent Synapse a notice of material breach and an increase in its required reserve balance. According to Synapse's court filing, the notice cited a failure to fully fund Evolve's FBO accounts, demanded a $50 million reserve and said Evolve would withhold all remaining compensation due to Synapse, which ultimately exceeded $43 million; a 2025 business-press report, citing court filings, put the withheld monthly payments at more than $40 million. 6 5 1

qualification
The amounts come from Synapse's filing and a press report of court filings; the notice itself is not retained.

attributedTwo days after the breach notice, Pathak sent Evolve a seven-page letter, seen by the business press, accusing the bank of persistent negligence through a misappropriation of consumer funds and demanding an independent investigation. The same letter acknowledged that Synapse itself might have incorrectly received $3.25 million from customer accounts, found through its own internal audit; Pathak wrote that Synapse would pay a little more than half of that amount, and Evolve agreed in an October 2023 contract to cover the rest. 1

qualification
Account of a letter and contract reviewed by a 2025 business-press report; neither document is retained in the record.

documentedThe asset purchase agreement Synapse signed in April 2024 refers to an 'Evolve Agreement' and to a letter agreement between Synapse and Evolve dated October 1, 2023, and made Evolve's written consent to the sale, including the assignment of the Evolve Agreement, a condition of closing. 7

attributedPathak's account, given in a November 11, 2024 interview, is that under the brokerage structure incoming funds were to land in end users' DDA accounts at Evolve, with the portion not needed for transactions swept out to AMG, but that in late September or early October 2023 Evolve stopped processing sweeps from Evolve to AMG without explanation. He said Synapse launched the brokerage sweep program around September or October 2023 in response to Evolve raising Synapse's reserve requirement and withholding interest owed to end users, fintech programs and Synapse, and that Synapse did not want Synapse Brokerage to contract with Evolve or keep its funds there because of known shortfalls. 8

qualification
Pathak's own account. The interviewer noted that Synapse Brokerage had been set up earlier and that Synapse had been migrating programs to the new structure since significantly earlier in 2023.

attributedPathak also said that Evolve was aware of, and acknowledged, that fees owed to TabaPay had been improperly debited from customer funds, while disputing whether that was the bank's fault. 8

qualification
Pathak's account in a November 2024 interview; no Evolve statement on TabaPay fees is retained.
response
Pathak denied that Synapse knowingly let fees Synapse owed be debited from end-user funds, saying it alerted Evolve and worked to fix such issues as soon as they came to its attention.

attributedThe CFPB alleges 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 consumers; that the two have publicly blamed each other; and that Synapse had not resolved its dispute with Evolve over the deficit by August 2025. 9 10

qualification
Allegation in the CFPB's complaint of August 21, 2025; in the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied it, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

attributedFINRA found that from around 2022 the ledgers kept by Synapse and its first deposit bank showed substantial differences in the end-user funds held in that bank's FBO accounts, with Synapse's records showing more than the bank said it held; that by September 2023 Synapse could not reconcile its ledger with the bank's records, the bank putting the shortfall in the tens of millions of dollars and each side asserting that the other's ledger was inaccurate; and that by May 2024 Synapse's records showed about $92 million more in end-user funds at the bank than the bank acknowledged. 3

qualification
Findings in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that they are not binding on any other person or entity named as a respondent in this or any other proceeding. The order does not name the bank, calling it DDA Bank 1.

analysisThe bank that FINRA calls 'DDA Bank 1' matches Evolve on every documented particular: a partnership with Synapse from around 2017, a services agreement that expired in September 2023 with a wind-down until May 2024, and the October 2023 departure of Synapse's largest client, a fintech with about $3 billion at the bank, to a direct relationship with it. The second bank, partnered from 2022 and terminating in March 2024, matches Lineage Bank. FINRA's order itself names neither bank. 3

qualification
An identification by comparison of documented particulars, not a statement made by FINRA.

attributedIn May 2024 Synapse told the bankruptcy court that, according to its schedule, Evolve owed depositors $150,437,659.89 as of May 14, 2024 while holding $102,694,725.72 in 49 FBO accounts in its sole custody, and that Evolve was obliged to fund the difference, which Synapse called the FBO Account Deficit. Synapse said that since October 2023 it had sent Evolve near-daily documentation that Evolve had to return more than $92 million to its FBO accounts; that Evolve had moved Synapse's reserve funds of more than $43 million partly to an FBO account to cover a deficiency of at least $35,322,630.78; and that Evolve still owed about $50 million. 5 2

qualification
Synapse's account in a court filing of May 23, 2024 (Doc 178), supported by declarations of Pathak and Guerin; Evolve disputes it. The schedule and the screenshot of Evolve's portal were exhibits to Pathak's declaration.
response
Evolve has said that Synapse's figures rest on inaccurate ledgers prepared by Synapse and that the funds Synapse claimed were not, and never had been, in Evolve's possession.

attributedThe schedule attached to Pathak's declaration attributes most of the $150,437,659.89 that Synapse said Evolve owed to depositors to the end users of two fintechs: Yotta Saving with $111,743,905.77 and Juno with $26,508,736.54. Smaller balances included Money App ($2,358,173.61), Changed Inc. ($1,792,001.61), Curacubby ($1,666,735.02), Gig Wage ($1,530,740.68) and YieldStreet ($1,329,495.70). 5

qualification
Synapse's own schedule of May 14, 2024, retained as a scanned exhibit; Evolve disputes the balances it shows.

documentedWhen Synapse filed for bankruptcy on April 22, 2024 it said it had reached a settlement with Evolve under which the bank had agreed to pay $2 million to the estate, and court approval of the settlement and mutual release with Evolve was a condition of the TabaPay asset sale. At a hearing on May 9, 2024 Synapse reported that the settlement had not been consummated because of disputes over Evolve funding a settlement payment, and the buyer said it would not proceed with the sale without it. 11 7 12

attributedSynapse's account of the collapse is that Evolve had agreed to fully fund its FBO accounts by April 22, 2024, repeatedly asked for more time, and then announced on the evening of May 8, 2024 that it had already fully funded a single FBO account on April 8, 2024 by transferring funds from Synapse's reserve account, paying itself almost $9 million in fees, and that nothing more was required; Synapse disputed that calculation, and TabaPay walked away from the purchase when it learned of it. Synapse added that Evolve had worked directly with TabaPay since about November 2023 to plan its support for the business after the acquisition. 5 13 12

qualification
Synapse's account in a court filing of May 23, 2024 (Doc 178), supported by declarations of Pathak and Guerin; Evolve disputes it.
response
An Evolve spokesperson said in May 2024 that Evolve was not party to TabaPay's agreement with Synapse and had no closing conditions to meet, and that the bank's settlement agreement with Synapse had a funding condition which Evolve satisfied. TabaPay said it withdrew because the closing conditions of the purchase agreement were not met.
outcome
TabaPay did not complete the purchase; the trustee later referred to its cancelled asset purchase.

attributedThe CFPB's account is that the buyer required Synapse and Evolve to reach agreement and ensure that the account balances at Evolve were fully funded as a condition of the purchase, and that the two could not resolve their dispute. 9 10

qualification
Allegation in the CFPB's complaint of August 21, 2025; in the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied it, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

attributedTabaPay's co-founder and president, Rodney Robinson, told the business press that all parties, including Evolve and TabaPay, had been willing to cover the gap in unaccounted customer funds until its true extent became clear, and described the matter as one of sloppy business practices that went on for years. 1

qualification
Statement of the prospective buyer to a 2025 business-press report.

attributedOn May 11, 2024, according to the CFPB, Synapse stopped maintaining Evolve's access to an online dashboard showing end users' balances and transactions and stopped sending Evolve the general ledger reports it had provided daily; Evolve then stopped processing transactions and froze all end-user activity, and Lineage did the same, so that consumers could not use debit cards, withdraw or transfer funds, pay bills or receive direct deposits. On May 13, 2024 Evolve asked the bankruptcy court to restore its access to Synapse's dashboard system or to let it close all of Synapse's program DDAs, saying it had been denied access to Synapse's computer systems and forced to freeze accounts; at the hearing that day, the trustee later reported, it was undisputed that end users had lost access to their funds. 9 10 12 5

qualification
Allegation in the CFPB's complaint of August 21, 2025; in the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied it, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.
response
Synapse told the court that Evolve froze all depositor accounts in response to a temporary pause in its dashboard access, and that Evolve had appropriate access to the dashboard from at least the morning of May 13, 2024.

attributedEvolve has said that the ledgers Synapse provided contained numerous material irregularities: in its July 2024 statement, that Synapse Brokerage end-user balances changed significantly from one day to the next without corresponding movement of funds, in some cases by millions of dollars; and in a June 2024 report to the trustee, that it held about $46 million in accounts created for payment processing on Synapse's behalf, was not and never had been a program bank of the cash management program, and had found numerous material discrepancies between the Synapse Brokerage ledgers and actual movements of funds into and out of Evolve. 14 4 15

qualification
Evolve's position as a party to the dispute over the shortfall.
response
Pathak has attributed the shortfall to Evolve's technical problems and fee debits rather than to Synapse's ledgers.

attributedAs an example, Evolve told the trustee in June 2024 that a Synapse ledger dated April 11, 2024 showed $109 million for Yotta end users at American Bank, AMG and six program banks reached through American Deposit Management, and $120.8 million in total at those program banks ($69.9 million for Yotta, $14.2 million for YieldStreet and $21.5 million for Juno), while the ledger of May 17, 2024 showed only $1.4 million of Yotta end-user funds at AMG and none elsewhere; Evolve said it had received no funds from those institutions in between. 14

qualification
Evolve's reading of Synapse ledgers, filed as an exhibit to the trustee's report of June 20, 2024.

attributedIn a 2025 letter to Synapse end users Evolve said that, under the Evolve-Synapse Master Bank Service Agreement, Synapse was contractually responsible for producing monthly end-user statements, and that its reconciliation had found two problems with them: statements Synapse gave Evolve for April and May 2024 showed many accounts moving from $0.00 at the end of April to substantial balances at the start of May with no corresponding transfers in Evolve's or the Federal Reserve's records, and Synapse had given Evolve and end users different statements, the end users' versions omitting transfers from Evolve to Synapse Brokerage. In one example from October 2023 the statement given to Evolve showed an ending balance of $25.45 and the statement given to the Yotta end user showed $2,862.82. 16

qualification
Evolve's account as a party to the dispute; the statements are reproduced only in its letter.

attributedEvolve engaged the forensic accounting firm Ankura Consulting Group, which completed a reconciliation on October 18, 2024. According to Evolve, Ankura found material irregularities and inaccuracies in the ledgers Synapse provided for Synapse Brokerage accounts, contradicted by Synapse's own transaction data and by Federal Reserve and Evolve records; because the other banks did not take part, Ankura could not determine where end users' funds sat beyond Evolve. Evolve said it was concerned that banks paying out on the basis of Synapse's ledgers had probably paid incorrect amounts. 16 17 18

qualification
Evolve's description of its consultant's work; the reconciliation itself is not public in the record.
outcome
AMG and Lineage called Evolve's suggestion that they might still hold substantial funds irresponsible and disingenuous, and in June 2025 the trustee reported that the exact amounts and sources of the shortfall had not been clearly established.

attributedThe two sides blame each other. Pathak has said the shortfall is rooted in discrepancies between Synapse's and Evolve's records and in fees Evolve debited from customer accounts, and in an August 20, 2024 post said Evolve needed to pay out customers and cover the deficit it had created. An Evolve spokesperson called Pathak's version simply not true, said Synapse had full visibility into its accounts at Evolve, and said Pathak and Synapse failed at their most critical responsibility, keeping accurate ledgers of where each end user's funds were held, which only Synapse was in a position to do. Evolve has also said that Pathak's claims rest on ledgers that are demonstrably inaccurate and that his company prepared, and Pathak has said that Evolve sent him a cease-and-desist letter after he posted what he described as an anonymised trial balance of funds Evolve held for end users. 8 19 1 9 17

qualification
Competing statements of the two parties; neither account has been adjudicated in the record.
outcome
No court or regulator has decided between the two accounts: the CFPB recorded that Synapse and Evolve had not resolved their dispute over the deficit by the time of the failed sale, and the trustee expressed no opinion on whether any partner bank's liability to end users was limited to the funds it held.

attributedOn its Synapse update page Evolve has said that, as part of a revised cash management program begun in the fall of 2023, Synapse created a subsidiary, Synapse Brokerage, and hastily migrated funds away from Evolve to AMG, along with Lineage and American Bank, which Evolve calls the Synapse ecosystem banks. 16 8

qualification
Evolve's account as a party to the dispute.
response
Pathak has said Synapse launched the brokerage sweep program around September or October 2023 in response to Evolve raising its reserve requirement and withholding interest payments.

sources in this section

  1. Media source · src-021 identified by category only · Media
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  8. Media source · src-025 identified by category only · Media
  9. Complaint, CFPB v. Synapse Financial Technologies, Inc. (Adv. No. 1:25-ap-01052-MB) Consumer Financial Protection Bureau · 21 Aug 2025
  10. Stipulated final judgment and order, CFPB v. Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 12 Sep 2025
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  12. Court record source · src-017 identified by category only · Court record
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  17. Court record source · src-065 identified by category only · Court record
  18. Court record source · src-042 identified by category only · Court record
  19. Media source · src-012 identified by category only · Media

4Mercury: Synapse's largest client and its departure

documentedMercury Technologies, Inc., a banking-services startup backed by Andreessen Horowitz, was Synapse's largest client. Former employees told the business press in 2025 that Mercury grew to represent around 60% of Synapse's revenue at its peak; Pathak put Mercury's share at about 35% of Synapse's business in September 2023. 1

qualification
Both shares are informal estimates from interviews: the 60% figure from unnamed former employees and the 35% figure from Pathak. Pathak declined to comment on the former employees' criticism.

documentedMercury left Synapse for a direct relationship with Evolve in the autumn of 2023. According to Synapse, Mercury gave notice on September 25, 2023, the day of Evolve's breach notice, that it would not renew its contract, and two days later Mercury and Evolve said they would move more than $3 billion of Mercury depositor funds from the Synapse program to a direct Evolve program; a technology-press timeline dates the end of both Evolve's and Mercury's relationships with Synapse to October 13, 2023. FINRA likewise found that in or around October 2023 Synapse's biggest customer, a fintech whose end users had about $3 billion at Synapse's first deposit bank, began partnering directly with that bank. 2 3 4 5 1

qualification
The FINRA finding is part of the order accepting Mark Paverman's settlement offer (neither admitted nor denied; not binding on others) and does not name the fintech or the bank.
response
A Mercury spokesperson said that after its experience with Synapse, Mercury had concluded that direct relationships and integrations with its partner banks were in the long-term interest of Mercury and its customers.

documentedSynapse confirmed on October 6, 2023 that it had laid off 86 people, about 40% of its staff, four months after cutting 18% of its workforce. A 2025 business-press report, describing the loss of Evolve and Mercury as a perfect storm, said Synapse's revenue had been cut by more than a third and put the October layoffs at more than 100 employees. 3 1

qualification
The published head-counts differ (86 in the company's confirmation as reported in 2024; more than 100 in a 2025 report).

attributedSynapse alleged in May 2024 that during the two weeks after the September 2023 notices, Mercury and Evolve improperly transferred more than $49 million of Synapse-related depositor funds to Mercury's direct program at Evolve without Synapse's review or participation. FINRA found that Synapse had contended its first deposit bank improperly migrated approximately $49 million more in end-user funds than it was entitled to during the fintech's transition. 2 5 1

qualification
Synapse's allegation in a court filing of May 23, 2024 (Doc 178); FINRA records it only as Synapse's contention. FINRA finding in its January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent, and it does not name the bank or the fintech.
response
Mercury strenuously denied moving any funds improperly; its spokesperson said that despite the lack of evidence provided by Synapse's former chief executive, Mercury investigated the claim fully, found no evidence to support it and did not over-migrate any funds during the transition.

attributedOn December 11, 2023 Mercury Technologies filed a petition in the Superior Court of California for the County of San Francisco to initiate proceedings for provisional relief in connection with an arbitrable controversy with Synapse. Mercury's lawsuit claimed, according to a business-press report, that Synapse had withheld $30 million in revenue, and Synapse countersued Mercury for more than $36 million; in its April 2024 first-day filing Synapse said it had substantial causes of action against Mercury. 6 7 1 8

qualification
The amounts are reported from the parties' filings, which are not retained; no arbitral or court outcome of the Mercury–Synapse dispute appears in the record.
outcome
No ruling or settlement of the dispute appears in the record; in June 2025 the trustee reported that the estate had looked for financing, including contingency counsel, to pursue any causes of action.

documentedSeparately from Synapse, Mercury, a fintech without a bank charter that works with partner banks, entered a settlement with the California DFPI in which the Commissioner found that its Twitter handle @bankmercury, website phrases such as 'building a bank for startups' and 'Mercury makes bank accounts', and use of the FDIC logo violated California law on the use of the word 'bank'; under the agreement the Commissioner ordered Mercury to cease and desist from using the word bank or banking in its name or Twitter handle and from using the FDIC logo in a misleading manner. Chief executive Immad Akhund signed for Mercury on December 24, 2021, and the agreement names neither Synapse nor any partner bank. 9

qualification
Mercury entered the agreement while neither admitting nor denying the Commissioner's findings.

unresolvedA trade newsletter headline of September 7, 2025 reported, citing sources, that the FBI was probing Evolve's fintech program and that Mercury was among the programs under scrutiny for transnational money movement. 10

qualification
Only the headline and subheading are retained; the article body is behind a paywall. The record contains no confirmation from the FBI, Evolve or Mercury and no charge against either company.

sources in this section

  1. Media source · src-021 identified by category only · Media
  2. Court record source · src-034 identified by category only · Court record
  3. Media source · src-102 identified by category only · Media
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  8. Court record source · src-042 identified by category only · Court record
  9. Settlement agreement between the Commissioner and Mercury Technologies, Inc. California Department of Financial Protection and Innovation · 3 Jan 2022
  10. Media source · src-084 identified by category only · Media

5The missing end-user funds: how big the shortfall was and who was paid

documentedWhen the trustee was appointed on May 24, 2024 the partner banks had lost access to Synapse's systems, had reason to believe Synapse's ledger was inaccurate and had found unexpected shortfalls in the FBO accounts they held, and they had no channels or safeguards for sharing data with one another. They agreed to pause distributions to end users while they investigated and reconciled accounts across the banks, and on May 31, 2024 the court approved a stipulated protective order allowing the banks and the trustee to share confidential trial balances and reconciliation data. 1

documentedThe trustee was told that Synapse and Synapse Brokerage, though separate companies, shared employees, functions and systems, including a single intertwined ledger database on MongoDB; that the brokerage's former president and its only other employee had been terminated effective May 24, 2024; and that the partner banks generally regarded May 17, 2024 as the last date on which Synapse's ledger was completed and accessible. The debtor had terminated all its employees and contractors on May 24, 2024 for lack of funds, leaving no one to interpret the ledger, and the estate could not afford a forensic accounting firm. Evolve told the trustee it could reconcile the DDA accounts it held through Synapse but not the brokerage accounts, for which it had only processed payments. 2

documentedIn her first report, filed on June 7, 2024, the trustee relayed the banks' figures as of June 6, 2024: they held about $180 million in DDA and FBO accounts associated with fintech end users and possible platform reserves, while the remaining trial balance, after distributions some banks made before her appointment, was about $265 million, implying a shortfall of about $85 million. The source of the shortfall, including whether end-user funds and negative-balance accounts had been moved among the banks, was not known. 2

documentedA week later, on June 13, 2024, the trustee reported that at least one partner bank now put the FBO shortfall at about $65 million to $96 million; the range reflected about $31 million of Synapse-related interest and rebate payments held at certain banks whose ownership by end users had yet to be determined. The banks' positions differed: American Bank reported no shortfall and said other banks owed it about $2,337,000 for unsettled debit transactions of May 8 to 23, 2024; AMG reported no shortfall and said it had reconciled all its FBO funds dollar for dollar against the Synapse trial balance; Evolve said it had not yet reconciled enough to determine whether it had a shortfall; and Lineage said it lacked the data to tell. 1

documentedThe demand deposit accounts were the smaller part of the problem: the banks told the trustee they had fully reconciled them, and no shortfall was reported between the DDA cash and the amounts owed to DDA end users on the Synapse trial balances. Evolve began paying out DDA funds on instructions from its regulator; by June 20, 2024 it had paid about $5.369 million to 3,317 end users on eight platforms. By November 12, 2024, of about $6.5 million in DDA funds held by Evolve and Lineage at the trustee's appointment, $5,884,188, about 91%, had been paid out. 1 3 4

documentedAt the trustee's appointment on May 24, 2024 the four banks held $219,077,467 of FBO funds connected with Synapse: $43,339 at American Bank, $110,290,040 at AMG National Trust, $46,926,558 at Evolve and $61,817,530 at Lineage. Evolve's funds came from net incoming payment activity of Synapse Brokerage, and Lineage's single FBO account combined DDA and FBO funds. 3 1

documentedAMG National Trust, which held about $110 million, paid out about $55 million immediately before the trustee's appointment and about $99 million to more than 31,000 end users of 12 platforms by June 20, 2024. By November 12, 2024 it had paid $109,869,963, 99.6% of its FBO funds, for about 91,400 end users; its payments included $2,360,734 for Juno end users, with $137,366 remaining, and $1,289,619 for Yotta end users, with $173,636 remaining. 3 4

documentedLineage Bank had paid out $49,200,617 of FBO funds by August 29, 2024 and $55,252,015 for 10,175 end users, 91% of its FBO funds, by November 12, 2024. 3

documentedEvolve completed its reconciliation as of October 18, 2024 and began notifying end users and paying them on November 4, 2024. By November 12, 2024 end users had chosen payment methods for more than $21 million of FBO funds from Evolve, including users of Juno, YieldStreet, Yotta and Clerkie, against the $46,926,558 Evolve held in May; the trustee's table shows 44% of Evolve's FBO funds distributed. Evolve declined, citing pending litigation, to give the trustee reconciled balances for individual end users or fintech partners, and the trustee wrote that she was disappointed in the results of Evolve's reconciliation, which notified some end users of amounts considerably less than shown on the Synapse ledger. 3

documentedOverall, by November 12, 2024, $187,121,978, about 85% of the $219,077,467 in FBO funds held at the trustee's appointment, had been distributed and $31,955,489 remained. The trustee stated that she expressed no opinion on whether any partner bank's liability to end users was limited to the amounts held in FBO or DDA accounts, and reported no change to the estimated shortfall of $65 million to $95 million. 3

documentedIn June 2025, seeking to end the case, the trustee told the court that after months of reconciliation the partner banks reported holding about $219 million of end-user cash at Synapse's closure in May 2024, that an apparent shortfall of $65 million to $95 million against the amounts recorded in Synapse's ledger had persisted throughout, and that the shortfall appeared to have existed before the bankruptcy. All partner banks had completed the reconciliation needed to return funds and most of the $219 million had been distributed, but the exact amount and sources of the shortfall had not been established: the estate lacked resources, and some banks declined to share reconciliation and distribution data voluntarily. 5

attributedThe CFPB alleges that with the trustee's help the partner banks determined that the funds they held for end users were less than the total in Synapse's records, a shortfall the trustee estimated at between $60 million and $90 million. Consumers had no access to their money for weeks or months while the banks reconciled their records with Synapse's; some distributions took more than eight months; in March 2025 the banks were still paying out, mostly small balances without valid addresses and returned payments; and many consumers had not received the full balance they held with their fintech platform as of May 17, 2024. 6 7 8

qualification
Allegation in the CFPB's complaint of August 21, 2025; in the stipulated judgment of September 12, 2025 the trustee and the debtor neither admitted nor denied it, but agreed that the facts alleged would be taken as true in any proceeding based on the judgment.

documentedPress reports in June 2024 put the number of people locked out of their accounts at more than 100,000, with combined deposits of $265 million citing the trustee, and at more than 200,000 customers; in July 2024 a technology-press timeline reported that about $158.6 million was still owed to end users. In September 2025 a trade-press report said that many end users of partner fintechs, including Yotta, Juno and Copper, still could not access their funds 17 months after the bankruptcy. 9 10 11 12

qualification
Press estimates; the trustee's reports give dollar amounts and per-bank counts of paid end users rather than a single total of affected people.

attributedLineage Bank told the trustee that it had processed ACH and wire transfers for Synapse under a master services agreement secured by a Synapse reserve account at Lineage, that in the fall of 2023 it discovered Synapse had transferred about $60 million of end-user funds into that reserve account, that it moved those funds into an FBO account for the benefit of the end users, and that in March 2024 it terminated the agreement for cause. A trade newsletter reported in October 2024, citing a partner bank and former employees, that Synapse had used customer funds to meet bank reserve requirements. 2 13 14 3

qualification
Lineage's account as relayed by the trustee and a newsletter headline; the reserve account records are not retained.
response
Asked in November 2024 whether Synapse ever used end-user funds inappropriately, Pathak said he was not aware of any misappropriation and called the allegation that Synapse used customer funds to meet reserve requirements at Lineage factually false; the interviewer noted that Synapse would have instructed Evolve to move the funds to Lineage and had represented them as its own.
outcome
By November 12, 2024 Lineage had paid out $55,252,015 to 10,175 end users, 91% of the FBO funds it held when the trustee was appointed.

attributedFINRA found that in 2022 Synapse's second deposit bank discovered significant data-integrity deficiencies and contradictions in Synapse's record-keeping, including an inability to provide reconciliations of end-user accounts, and that around December 2022 it required Synapse to maintain a $60 million minimum in end-user account balances. 15

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent, and it refers to the bank only as DDA Bank 2.

attributedLineage told the trustee in June 2024 that the Synapse trial balance available to it was contradictory, did not match the flow of funds and could not be verified for platforms or individual end users; that before the bankruptcy Synapse frequently moved lump sums, aggregating hundreds of millions of dollars, between banks without allocating them to fintechs or end users; that Synapse's final post-bankruptcy trial balance assigned millions of dollars of missing funds to banks apparently arbitrarily; and that one bank's distribution of more than $50 million, mainly to one fintech's end users, before the trustee's appointment complicated a fair allocation. At the hearing of May 24, 2024 Lineage's counsel said the records were demonstrably flawed and could not be verified, and that the ledger did not match the flow of funds the bank could see. 4 12

qualification
Lineage's position as a partner bank, filed as an exhibit to the trustee's report of June 20, 2024 and stated at the May 24, 2024 hearing.

attributedIn November 2024 AMG and Lineage set out their cash flows with Evolve: Lineage had sent $1,509,088,460.82 to Evolve and received $210,320,593.25, a net $1,298,767,867.57 to Evolve, while AMG had received a net $341,200,090.03 from Evolve, for a combined net movement of $957,567,777.54 to Evolve. The two banks said they had paid out according to Synapse's trial balances as confirmed by reconciliation, rejected Evolve's suggestion that they might still hold substantial funds, and urged the banks to establish why the Synapse trial balances exceeded the funds held across the banks; they noted that during the wind-down AMG received more than $80 million from ADMC for processing end-user payments. 3

qualification
Position of AMG and Lineage in an exhibit to the trustee's report of November 12, 2024, signed by their chief executives; Evolve's own account of the flows is not retained.

documentedIn 2023 Synapse's audit committee engaged Kroll, Inc. to audit and reconcile Synapse's ledgers, and in June 2024 the trustee was meeting Kroll to discuss the findings of that work on Synapse's systems, transaction history and governance. 1

attributedA February 2025 press report, relaying a newspaper investigation, states that Victor Medeiros, formerly a senior director in Synapse's finance department, warned Kroll's accountants in 2023 that customer accounts were short by millions of dollars because Synapse had held onto some of their funds, specifically that it had not credited customers with the full interest due, leaving them more than $3 million short as of mid-2023. According to the report, Kroll checked the books and confirmed the estimate to the board, which demanded that the shortfall be fixed at once, but Synapse said it could not cover the losses. 16 17

qualification
Second-hand press account of an investigation by another outlet; neither Kroll's work nor board minutes are retained, and no response from Synapse's former directors to this account appears in the record.
response
A lawyer for Medeiros did not respond to requests for comment.

attributedPathak said in November 2024 that Synapse's board, which at various times included Angela Strange of Andreessen Horowitz, Schwark Satyavolu of Trinity Ventures and Arjan Schütte of Core Innovation Capital, was broadly aware of the problems Synapse faced, was trying to do the right thing, and asked him not to shut down and escalate. 14 17

qualification
Pathak's characterisation; no statement by the named directors or their firms is retained, and the investors declined to comment or did not respond to another outlet.

documentedOn June 28, 2024 Senators Sherrod Brown, Ron Wyden, Tammy Baldwin and John Fetterman wrote to Synapse's major investors, its principal bank and fintech partners, among them W. Scott Stafford as president and chief executive of Evolve Bank & Trust, and its former chief executive, Sankaet Pathak, that customers had been unable to reach their money since mid-May, that there was a potential shortfall of $65 million to $96 million between what consumers were owed and what the partner banks held, and that as major equity holders, operators of Synapse-dependent services and partner banks it was ultimately the recipients' responsibility to ensure the safety and accessibility of end-user funds; they urged the recipients to pool resources to release all frozen deposits immediately. 18 19

qualification
A request from members of Congress; it assigns no legal liability.

documentedReplying on July 2, 2024 to the trustee's letter of June 20, the Federal Reserve Board's general counsel, Mark Van Der Weide, expressed sincere concern for harmed consumers and wrote that identifying exact balances was complex because Synapse-related funds sat at several banks, often in accounts held for the benefit of multiple users; he said the Federal Reserve, as Evolve's primary federal regulator, expected supervised banks to return customer funds consistent with applicable law and would continue to monitor Evolve's progress in returning customer funds affected by the bankruptcy. 20

documentedOn July 1, 2024 the trustee's counsel wrote to MongoDB, which had said it intended to terminate services on the debtor's subscriptions because post-petition bills were unpaid, that its systems held Synapse records not found anywhere else and that reconciling Synapse's ledger with the banks' ledgers was needed both to let the banks distribute more than $100 million they held for end users and to identify the origin of a $65 million to $96 million shortfall. 20

documentedBy November 2024 affected end users had appealed Evolve's reconciliation results, contacted lawmakers and filed claims with the FDIC, the CFPB and the Federal Reserve Bank of St. Louis, Evolve's primary regulator; a website set up by a group of users coordinated complaints to the Federal Reserve against Evolve, Lineage, AMG and American Bank. 21

attributedAfter Evolve's November 2024 payouts, customers of Yotta and Juno reported receiving small fractions of their balances, such as $0.84 on $10,328 and $9.01 on $28,660 in screenshots seen by the trade press. Yotta said a survey of more than 8,700 of its users with deposits of more than $46.7 million showed Evolve payments of $7.7 million, a 16.5% payout ratio, whereas the Synapse trial balance showed Evolve owing about $158 million; it also said Evolve's reconciliation covered only the period from September 30, 2023, although Synapse had reported discrepancies earlier, and that Evolve refused to share data on its payments and on ecosystem balances. A Yotta spokesperson said Evolve had acknowledged knowing of the shortfall since at least September 2023 without telling Yotta. 21 22 3

qualification
Yotta's survey and statements as a party in litigation with Evolve, and customer screenshots reported by the trade press.
response
Evolve declined to comment further to the trade press on the reconciliation; it has maintained that the shortfall arose from inaccuracies in Synapse's ledger.
outcome
Evolve let end users choose a payment method until December 4, 2024, after which it would send checks; the trustee's November 2024 report showed 44% of the FBO funds Evolve held distributed.

documentedThe CFPB's Civil Penalty Fund allocated $46,248,291 for victims in the Synapse Financial Technologies, Inc. matter in its November 28, 2025 allocation and a further $8,965,767 on May 29, 2026; Yotta's status page reported that the timing and amounts of the CFPB's payments remained to be determined. 23 22

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  15. Regulatory record source · src-009 identified by category only · Regulatory record
  16. Media source · src-076 identified by category only · Media
  17. Media source · src-021 identified by category only · Media
  18. Senators' letter to Sankaet Pathak of June 28, 2024 Office of Senator Tammy Baldwin, U.S. Senate · 28 Jun 2024
  19. Senators' letter to W. Scott Stafford, Evolve Bank & Trust, of June 28, 2024 U.S. Senate Committee on Banking, Housing, and Urban Affairs · 28 Jun 2024
  20. Court record source · src-033 identified by category only · Court record
  21. Media source · src-030 identified by category only · Media
  22. Company statement source · src-051 identified by category only · Company statement
  23. Civil Penalty Fund allocations Consumer Financial Protection Bureau · 29 May 2026

6The Synapse bankruptcy: from a planned sale to dismissal

documentedBefore filing, the debtor said, it explored investment, restructuring and sale options: around the spring of 2022 it engaged William Blair as investment banker to seek new capital and worked with Sherwood Partners, Inc. as financial adviser; it later replaced William Blair and sought to engage Jefferies LLC to market the company for sale as a going concern, receiving several offers. 1

documentedBy unanimous written consent dated April 10 and 11, 2024, the board of directors of Synapse Financial Technologies, Inc., signed by Sankaet Pathak, Doug Marchant and Hillary Quirk as all of its members, resolved to file a voluntary Chapter 11 petition in the Central District of California and designated Pathak as the responsible party and designated officer of the company during the case. 2

documentedOn April 19, 2024 Synapse signed an asset purchase agreement under which TabaPay, or its designee, would buy substantially all of its assets, including its equity in its two subsidiaries, for $9,700,000 in cash plus other consideration such as assumed contracts. The sale was to close in three stages: the main assets by April 30, 2024, subject among other conditions to program reconciliations and third-party consents; the broker-dealer subsidiary by May 30, 2024, after a FINRA change-of-control process; and the lending subsidiary by April 19, 2025. At the petition date the debtor described its primary assets as about $2 million in cash, its technology platform, customer agreements and the equity in its subsidiaries, and possible claims against third parties. 1

documentedSynapse Financial Technologies, Inc. filed a voluntary Chapter 11 petition on April 22, 2024 in the U.S. Bankruptcy Court for the Central District of California, San Fernando Valley Division (Case No. 1:24-bk-10646-MB, Judge Martin R. Barash). Sankaet Pathak signed the petition as chief executive officer; the debtor was represented by Levene, Neale, Bender, Yoo & Golubchik L.L.P., and an official committee of unsecured creditors was later appointed. 3 2

documentedThe petition estimated 50 to 99 creditors and assets and liabilities each in the range of $10,000,001 to $50 million, according to a trade-press report. The list of the 20 largest unsecured creditors was headed by Kroll Associates, Inc. ($473,662.28), Thomson Reuters ($290,822.50, disputed), Lineage Bank ($276,812.26, disputed), Amazon Web Services ($261,509.36), Jones Day ($229,275.00), Trulioo ($225,754.20) and MasterCard International ($210,900.83, disputed); TabaPay, Inc. ($67,500.02) and Yotta Technologies Inc ($65,172.33) were also listed. 4 2

documentedThe debtor stated that its only intellectual-property asset was a registered trademark and that it had no copyright or patent assets. 5

documentedUnder a Loan and Security Agreement of February 19, 2021, Silicon Valley Bank agreed to lend Synapse and Synapse Credit in two tranches of up to $4 million and up to $2 million, interest-only until January 31, 2022 and then repayable in 36 monthly instalments, secured on all of Synapse's personal property other than intellectual property; a UCC financing statement was filed in Delaware the same day. The debtor described SVB as the predecessor of First-Citizens Bank & Trust Company and estimated about $1.5 million owing as of April 30, 2024. 5

documentedSilicon Valley Bank was acquired by First-Citizens Bank & Trust Company after it entered receivership; in 2024 the creditor was listed as Silicon Valley Bank, a division of First-Citizens Bank & Trust Company, Synapse's primary operating accounts were held at First Citizens Bank as acquirer of Silicon Valley Bank, and by June 2025 First Citizens was owed about $1.5 million under the SVB loan. 6 1 7

documentedUnder a Plain English Growth Capital Loan and Security Agreement of July 29, 2022, lenders identified as TPVG, TPVL and TPC, with TriplePoint Capital LLC as collateral agent, made three facilities available to Synapse: $9 million, $6 million subject to milestones and warrant agreements, and $5 million subject to milestones. TriplePoint took a lien on all of Synapse's personal property, filed in Delaware the same day, with deposit account control agreements over accounts at SVB, Evolve and Independent Bank, and its claims were subordinated to SVB's senior debt. Before the filing TriplePoint agreed to accept a discounted payoff of $7,199,624.29 if paid by May 6, 2024. 5 1

documentedTriplePoint Venture Growth BDC Corp. listed in its portfolio a growth capital loan to Synapse Financial Technologies, Inc. acquired on July 29, 2022 at Prime plus 5.75% with a 9.75% floor and a 4.00% end-of-term payment, maturing on July 31, 2025, and a warrant for 3,913 shares of Synapse's non-voting stock acquired the same day, according to its 2024 registration statement on Form N-2. 8

documentedIn June 2025 the trustee reported that First Citizens was owed about $1.5 million and TriplePoint about $7.2 million, both secured on Synapse's property, and that under the cash collateral orders both lenders had received adequate-protection liens and superpriority administrative claims. A stipulation between the trustee and First Citizens on applying cash collateral was filed on November 3, 2025 and approved by the court on November 6, 2025. 3 7

documentedThe court approved bidding procedures on May 1, 2024 and set the sale hearing for May 9. At that hearing Synapse reported that it had failed to reach a settlement with Evolve, and the buyer said it would not proceed without one, so the sale process was halted; the trustee later referred to TabaPay's cancelled asset purchase. 6 7

documentedOn May 15, 2024 the United States Trustee for the Central District of California filed an emergency motion to convert the case to Chapter 7 or, alternatively, to appoint a Chapter 11 trustee; according to a technology-press account of the motion, the U.S. Trustee said Synapse had grossly mismanaged its estate, with losses continuing and little reasonable likelihood of reorganization. 9 6

documentedOn May 24, 2024 the debtor reported that it would run out of cash, terminate its remaining employees and cease operations by the end of that day, and that without new funding, which did not appear available, there was no chance of a reorganization or a going-concern sale. At the hearing that day one of its lawyers told the court, according to a press report, that all of the company's funds were gone. 10 7 11

documentedGranting the U.S. Trustee's motion on May 24, 2024, Judge Barash ordered the appointment of a Chapter 11 trustee on the basis of findings stated orally at the hearing, directed the trustee to meet and confer with the fintech platforms, partner banks and secured lenders and to file weekly status reports from June 6, 2024, and ordered the debtor, its subsidiaries, officers, directors, shareholders and current and former employees to preserve all evidence and not to delete, alter or conceal any documents or electronic information about the debtor's business. The U.S. Trustee appointed Jelena McWilliams, a former chair of the FDIC, as trustee. 12 3 13 6

attributedA 2025 business-press account says that by May 2024 the bankruptcy court had removed Synapse's management from decision-making, citing gross mismanagement, when it appointed McWilliams to take over day-to-day operations. 13 12

qualification
Press characterisation; the appointment order itself rests on findings stated orally at the hearing, which are not retained in the record.
outcome
The court granted the U.S. Trustee's motion on May 24, 2024 and ordered the appointment of a Chapter 11 trustee; Jelena McWilliams was appointed.

documentedAt the May 24, 2024 hearing, as reported by the press, the judge ordered weekly status reports and in-person status conferences, reiterated the preservation order for Synapse's current and former employees, and said it was a horrible situation for customers who could not buy food or pay their mortgage or rent. 11

documentedThe trustee's second report described Sankaet Pathak and Tracey Guerin as former Synapse officers who testified under oath at the creditors' meeting on June 10, 2024; Pam Wismer, an independent contractor from Ascent CFO Solutions, had provided part-time chief financial officer services to the debtor, and Jack Doan was its former chief human resources officer. The first report described Guerin as the debtor's former general counsel. 6 14

documentedThe trustee obtained access to the debtor's MongoDB database, Slack, Rippling HR system and the data room prepared for TabaPay's due diligence; administrative access to MongoDB came from former officers. Master credentials to Synapse's Amazon Web Services environment, where ledger records were also stored, were reported to be known only to two former engineers, who did not at first respond and later said they no longer had access. 6 15

documentedAccording to Yotta's status page, the trustee reported in early July 2024 that B. Riley Financial, Inc. had been retained to help with forensic accounting and the management of the Synapse estate. 16

documentedIn June 2024 the trustee reported that the debtor appeared to have no available liquidity and no arrangement with its secured lenders to use cash collateral if the estate obtained funding; the estate could not pay its counsel or financial advisers throughout the trustee's appointment. 6 7

documentedThe trustee tried to sell the remaining assets, chiefly the technology platform and data. Pathak's declaration of May 6, 2024 had put the net book value of office equipment at $9,931 and of all intellectual property at $408,544, and the trustee considered the customer lists and goodwill worthless. The court approved bidding procedures on October 17, 2024, but no qualified bid arrived by the extended deadline of November 11, 2024, the auction was adjourned, and bids received did not exceed the secured liens or justify the cost of completing a sale. 7

documentedThe trustee said the debtor might hold valuable claims against third parties, but the estate had no funds to investigate or litigate them and she found no contingency-counsel or sale arrangement that would return meaningful value; she also noted that the ledger data held by MongoDB and Amazon Web Services might matter to affected people, while the estate could not pay for its upkeep. 7

documentedOn the trustee's motion of June 5, 2025 to convert or dismiss the case, the court entered an order approving dismissal of the Chapter 11 case on November 12, 2025. On June 29, 2026 the clerk closed the case, discharged the trustee and exonerated her bond. 3

sources in this section

  1. Court record source · src-003 identified by category only · Court record
  2. Court record source · src-022 identified by category only · Court record
  3. Court record source · src-001 identified by category only · Court record
  4. Media source · src-049 identified by category only · Media
  5. Court record source · src-023 identified by category only · Court record
  6. Court record source · src-017 identified by category only · Court record
  7. Court record source · src-042 identified by category only · Court record
  8. Registration statement on Form N-2 of TriplePoint Venture Growth BDC Corp. (portfolio schedule) U.S. Securities and Exchange Commission (EDGAR) · 5 Mar 2024
  9. Media source · src-102 identified by category only · Media
  10. Regulatory record source · src-009 identified by category only · Regulatory record
  11. Media source · src-093 identified by category only · Media
  12. Court record source · src-054 identified by category only · Court record
  13. Media source · src-021 identified by category only · Media
  14. Court record source · src-031 identified by category only · Court record
  15. Court record source · src-032 identified by category only · Court record
  16. Company statement source · src-051 identified by category only · Company statement

7Synapse Brokerage: the cash management program, FINRA and California

attributedFINRA found that, to move away from its first deposit bank amid their dispute, Synapse changed its operating model so that its dormant broker-dealer, Synapse Brokerage, would offer services directly to end users; Jeffrey Stanley was warned that the firm was not ready but decided to proceed. In September 2023 Synapse Brokerage launched a cash management program in which deposited funds were spread among banks that were not FINRA members with the aim of maximising FDIC coverage. End users who did not opt out became Synapse Brokerage customers but kept using their fintech app; the program was the firm's only line of business, and it offered no securities products. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedUnder the program as FINRA describes it, customers first had to deposit money in an account at one of Synapse's deposit banks, from which it was to be swept to a Synapse Brokerage omnibus account at a third bank and spread among multiple program banks; Synapse kept the ledger of each customer's brokerage balance. Synapse Brokerage earned substantial revenue from interest and fees paid by the program banks, passing part to fintechs or customers. From September 2023 to mid-May 2024 customers could not withdraw directly from the program banks: funds had to move back through the deposit banks first. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedFINRA found that brokerage customers' funds at the second deposit bank sat in an FBO account in Synapse Financial Technologies' name, and that after December 2023 the omnibus accounts at the first bank were retitled 'Synapse Financial Technologies Synapse FBO Synapse Brokerage ACH Customers' and '... Wire Customers'; by January 2024 all customer funds sent from Synapse Brokerage to both banks were held in omnibus accounts in the parent's name rather than the brokerage's or the banks'. Synapse's terms of service, to which the opt-out notices referred customers, said that Synapse did not and would not control, transmit or hold their funds, and customers were not told otherwise. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedSynapse Brokerage depended on the parent's staff, FINRA found. Jeffrey Stanley was employed by Synapse Financial Technologies from January 2023 to May 2024, worked only on the brokerage and, although its chief executive and president from December 2023, reported to the parent's unregistered chief compliance officer; the only other registered employee split his time with the parent and reported to its chief technology officer. The remaining registered personnel were part-time outside consultants, including Mark Paverman, who was anti-money-laundering compliance officer throughout, nominal chief executive until December 2023 and chief compliance officer afterwards, and spent about five hours a week on the firm's business. In December 2023 Stanley signed an amended intercompany service and expense sharing agreement under which the brokerage paid the parent to furnish personnel and services. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedAccording to FINRA, unregistered staff of the parent onboarded brokerage customers, negotiated with fintechs, designed the program's technology, maintained the brokerage's ledger, directed transfers of customer funds, handled anti-money-laundering reviews and selected the program banks; they had authority over the brokerage's bank accounts and on at least two occasions moved money out of a brokerage account without approval from any registered person. No one at Synapse Brokerage had direct access to its ledgers, whose contents were available only through reports from the parent's staff. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedFintechs emailed opt-out notices, worded by Synapse Brokerage, from about July 2023 to February 2024: unless end users contacted the firm, a brokerage account would be opened in their name and their deposit-bank funds moved into the program, and continued use of the app meant accepting the brokerage's customer agreement. FINRA gives examples: within eight days of one fintech's notice on October 5, 2023, about $200 million belonging to about 650,000 end users moved from the first deposit bank into the program, and within a week of another's notice on October 13, 2023 about $60 million of about 32,000 users moved. By the end of November 2023 more than two million accounts had been opened and about $388 million transferred; at one fintech only about 29,000 of some 90,000 recipients opened the email and 123 clicked the links to the agreement. Stanley approved the opening of more than two million accounts without any affirmative customer authorisation, FINRA found. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedFINRA found that around December 31, 2023 the first deposit bank stopped sweeping brokerage customers' deposits into Synapse Brokerage, without customers being told, and that Synapse then began reallocating brokerage customers' funds by changing values on its ledger with no accompanying transfer, so that only Synapse and the brokerage could know. On or about April 30, 2024, a week after the bankruptcy filing, Synapse moved more than $85 million of brokerage funds belonging to end users of one fintech on its ledger from the program banks to the first deposit bank, offsetting it by moving other fintechs' users' funds the other way, with no wire or ACH transfer and without customer authorisation; the reallocations appeared on Synapse's trial balance reports. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

attributedFrom May 11, 2024, FINRA found, Synapse Brokerage customers could not withdraw any money, because withdrawals had to pass through the deposit banks: the first bank had refused to process payments for the brokerage after its dispute with Synapse came to a head, and the second had terminated its agreement. About $110 million recorded at the program banks was returned to customers at the end of May and in June 2024; funds allocated to the first bank, largely the end-user funds reallocated on April 30, stayed frozen until that bank began releasing funds in November 2024, and those customers recovered only a fraction. Stanley had routinely approved transfers from the program banks to Synapse's omnibus account at the second bank to meet its $60 million minimum, without telling customers; that bank froze about $62 million from May to August 2024 and had returned about 90% by the end of September 2024. 1

qualification
Finding in FINRA's January 28, 2026 order accepting Mark Paverman's offer of settlement, to which he consented without admitting or denying the allegations; the order states that its findings are not binding on any other person or entity named as a respondent. The order refers to Synapse's deposit banks as DDA Bank 1 and DDA Bank 2 and to fintech clients by number.

documentedJeffrey Alan Stanley was registered as a general securities principal through Synapse Brokerage from February 2023 to June 2024. According to FINRA he functionally acted as its chief executive before December 2023, supervising the firm, approving account openings and fund transfers and serving as its point of contact with Synapse, and was its president and chief executive in title from December 2023 to May 2024; the firm filed a Form U5 on June 21, 2024 reporting his voluntary departure. California's DFPI describes him as chief executive and a control person of the firm from December 2023 to July 2024. His FINRA record lists earlier posts as chief operating officer of Insperex (2020–2022) and as chief operating officer and chief risk officer of D.A. Davidson & Co. (2012–2020), and earlier registrations with Sterne, Agee & Leach and FTN Financial Securities. 1 2 3

documentedMark Elliot Paverman was registered as a general securities principal through Synapse Brokerage from January 2021 to January 2025, while also registered in that capacity with about 30 other FINRA member firms. The firm's records identified him as its president and chief executive from March 2021 to December 2023, and he was chief compliance officer from December 2023 to January 2025; the firm filed a Form U5 on January 13, 2025 reporting his voluntary departure. FINRA found that he was an outside part-time consultant who spent about five hours a week on the firm; his FINRA record shows him as principal of his own compliance consultancy in Boca Raton, Florida since June 2019. 1 4 5

documentedCalifornia's DFPI states that Sankaet Pathak, founder and chief executive of Synapse Financial Technologies, was a control person of Synapse Brokerage from June 2020. 2

qualification
The end date of Pathak's control-person status is cut off in the retained copy of the DFPI accusation.

attributedOn August 28, 2025 FINRA's Department of Enforcement filed disciplinary proceeding No. 2023080111701 against Stanley and Paverman. The complaint alleged that Stanley failed to reasonably supervise the firm's cash management program: he approved the opening of hundreds of thousands of brokerage accounts and transfers of customer funds without adequate customer authorisation, the firm under him failed to detect the ledger reallocation of tens of millions of dollars to a bank, and he failed to supervise the parent's unregistered staff or investigate red flags of ledger discrepancies. It alleged that Paverman caused the firm to fail to preserve electronic communications and falsely certified to FINRA that the firm contracted directly with its records vendor and had independent access to its records. 6 7 1 3

qualification
Allegations of a self-regulatory organisation at the time of filing; their resolution is set out in the separate settlement orders.
response
Stanley's attorney, Paul Vorndran, said Stanley denied FINRA's allegations that he engaged in any misconduct and intended to defend himself vigorously. Paverman and Pathak did not respond to a trade-press request for comment.
outcome
Both respondents later settled without admitting or denying the allegations: Paverman by an order of January 28, 2026 and Stanley by an order of May 22, 2026.

documentedIn an order of January 28, 2026 accepting his offer of settlement, Paverman consented, without admitting or denying the allegations, to findings that he caused Synapse Brokerage to violate FINRA Rules 4511 and 2010 by failing to preserve, from December 2023 to June 2024, emails of three registered representatives, instant messages of all of them and communications of parent-company staff performing brokerage functions, and that in May 2023 he gave FINRA a false undertaking that the firm contracted directly with its records vendor and had independent access to its records, when the contract was the parent's and the firm depended on the parent for access. He was suspended for 12 months in all principal capacities, from February 17, 2026 to February 16, 2027, fined $20,000 and required to requalify as a general securities principal. 1 8

documentedOn May 22, 2026 FINRA accepted Stanley's offer of settlement in the same proceeding. Without admitting or denying the allegations, he consented to findings that from at least September 2023 to May 2024 the firm, acting through him, failed to maintain a supervisory system reasonably designed to ensure compliance with FINRA rules: he approved opening cash management accounts and moving customer funds without adequate authorisation, let a non-member parent perform significant brokerage functions including keeping the ledger used to reconcile customer balances without supervision, and failed to investigate red flags of substantial discrepancies between the parent's ledgers and those of third-party banks. He was suspended from any principal capacity for 12 months (to May 21, 2027) and from all capacities for four months (to September 21, 2026) and must requalify by examination; in light of his financial status no monetary sanction was imposed. 3

documentedFINRA suspended Synapse Brokerage on March 18, 2025 for failing to file its December 2024 annual audit report and failing to keep its Form BD current and accurate, and on June 23, 2025 expelled it from membership because it had not asked for the suspensions to be lifted within three months. 4

documentedCalifornia's Department of Financial Protection and Innovation began examining Synapse Brokerage's books and records on June 14, 2024. On October 11, 2024 Commissioner Clothilde V. Hewlett issued an accusation and notice of intent to revoke its broker-dealer certificate, finding that the firm had failed to produce required records (of beneficial owners, written customer complaints, communications and agreements with clients and financial institutions), that its net capital in May 2024 was $217,972, $32,028 short of the $250,000 minimum, and that it had not filed monthly interim financial reports from May to September 2024. 2

documentedOn January 22, 2025 the Acting Commissioner revoked Synapse Brokerage's broker-dealer certificate, first issued on March 22, 2010, after the firm did not request a hearing. DFPI's statement in the firm's regulatory record notes that the parent's bankruptcy left thousands of the brokerage's clients unable to reach their funds and that, while some had their funds returned, an estimated $60 million or more was unaccounted for as of January 2025. 4 9

documentedBy an order of July 10, 2024, effective immediately, the Commissioner of Financial Protection and Innovation revoked Synapse Credit LLC's California Financing Law license (No. 60DBO-113301); Synapse Credit had been served with the notice and accusation in June 2024 and did not request a hearing. DFPI later said it was the first regulator to take formal action after the Synapse bankruptcy. 10 11

sources in this section

  1. Regulatory record source · src-009 identified by category only · Regulatory record
  2. Accusation and notice of intent to revoke the broker-dealer certificate of Synapse Brokerage LLC California Department of Financial Protection and Innovation · 11 Oct 2024
  3. BrokerCheck report: Jeffrey Alan Stanley Financial Industry Regulatory Authority (FINRA)
  4. BrokerCheck report: Synapse Brokerage LLC (CRD 137662) Financial Industry Regulatory Authority (FINRA)
  5. BrokerCheck report: Mark Elliot Paverman Financial Industry Regulatory Authority (FINRA)
  6. Disciplinary and Other FINRA Actions, October 2025 Financial Industry Regulatory Authority (FINRA) · Oct 2025
  7. Media source · src-029 identified by category only · Media
  8. Disciplinary and Other FINRA Actions, March 2026 Financial Industry Regulatory Authority (FINRA) · Mar 2026
  9. Order revoking Synapse Brokerage LLC's broker-dealer certificate California Department of Financial Protection and Innovation · 22 Jan 2025
  10. Order revoking Synapse Credit LLC's California Financing Law license California Department of Financial Protection and Innovation · 10 Jul 2024
  11. DFPI press release on the $1 million settlement with Yotta Technologies California Department of Financial Protection and Innovation · May 2026

8Regulatory actions involving Synapse and its partner banks

documentedOn August 21, 2025 the CFPB filed an adversary complaint against Synapse Financial Technologies, Inc. within its bankruptcy case (Adv. No. 1:25-ap-01052-MB), together with a proposed stipulated final judgment. The single count alleged that Synapse, as a service provider to the fintech platforms and to Evolve, engaged in unfair acts or practices under sections 1031 and 1036 of the Consumer Financial Protection Act by failing to keep adequate records of where consumers' funds were and to ensure those records matched the partner banks' records, so that consumers lost access to their money. 1 2 3 4

response
The trustee and the debtor neither admitted nor denied the allegations, and the CFPB made no allegations against the trustee.
outcome
Resolved by the stipulated final judgment entered on September 12, 2025, which bans Synapse from deposit-taking, money transmission, custody of funds and payment processing, bars the sale of customer information and imposes a $1 penalty; the CFPB then allocated money from its Civil Penalty Fund to affected consumers.

documentedJudge Barash entered the stipulated final judgment on September 12, 2025. The trustee, acting for the debtor, agreed to it without adjudication of any issue of fact or law; she and the debtor neither admitted nor denied the complaint's allegations, the CFPB made no allegations against the trustee, and the facts alleged were to be taken as true in any proceeding based on the judgment. The judgment permanently bars Synapse from taking part in or assisting deposit-taking, money transmission, custody of funds or payment processing, bars the debtor and the trustee from selling customer information, and imposes a civil money penalty of $1, allowed as a general unsecured claim, which the CFPB said enabled it to use its Civil Penalty Fund to compensate harmed consumers. 3 1

documentedThe judgment defines the harm to affected consumers, anyone with an account at a fintech platform served by Synapse on May 17, 2024, as the difference between each consumer's balance with the platform on that date and the sum of distributions paid to the consumer by Evolve Bank & Trust, AMG National Trust Bank or Lineage Bank since then, plus prejudgment interest. 3

documentedIn a consent order in Case No. 16-041 (filed June 2020), the New Hampshire Banking Department stated its contention that SynapseFi, formerly Synapse Payments LLC, had conducted 1,187 unlicensed money transmissions for New Hampshire entities from at least 2015 to 2017, collecting fees of $82.60, and noted that the company had cooperated fully and stopped the activity in 2017. The company agreed to continue refraining from unlicensed money transmission, to amend its third-party contracts so that it was not positioned to transmit money, and to pay an administrative fine of $1,582.60; Sankaet Pathak signed as chief executive officer. 5 6

qualification
The violations are the Department's contentions; the company waived a hearing and entered the order by consent.

documentedOn September 26, 2022 Connecticut's Banking Commissioner, Jorge L. Perez, issued Synapse Credit LLC a notice of intent to refuse to renew its small loan licence and of its right to a hearing: its renewal application of December 30, 2021 remained pending because it had not filed audited financial statements for 2020 and 2021, it had submitted only unaudited statements, and it had not answered a compliance letter of May 5, 2022 or surrendered the licence. The notice was sent to Michael Rasic, chief financial officer and chief business officer, as Synapse Credit's primary contact. 7

qualification
No later decision on the renewal appears in the record.

documentedOn June 11, 2024 the Federal Reserve Board and the Arkansas State Bank Department issued a cease-and-desist order, by consent, against Evolve Bancorp, Inc. and Evolve Bank & Trust (Docket Nos. 24-012-B-HC and 24-012-B-SM). It recites examinations of August 11, 2023, August 30, 2023 and January 10, 2024 that found deficiencies in risk management and consumer compliance at the bank's Open Banking Division, which served fintech partners, and in anti-money-laundering and sanctions compliance. The order requires, among other things, controls ensuring that the ledger and sub-ledger responsibilities of the bank and its fintech partners are clearly defined, including in a business disruption, and bars the bank without prior supervisory approval from adding fintech partners, products or programs to the division; before exiting a fintech relationship the bank must give supervisors an analysis of the impact on its liquidity. 8 9

qualification
The bank consented to the order without a formal proceeding or adjudication of any issue of fact or law; the Federal Reserve said the action was separate from the Synapse bankruptcy.

documentedOn January 30, 2024 the FDIC issued a consent order against Lineage Bank of Franklin, Tennessee (FDIC-23-0041b), to which the bank consented without admitting or denying charges of unsafe or unsound practices relating to its third-party risk management program and its fintech partners. The order requires the board to receive monthly reports on fintech partners' FBO-account and ACH activity and its effect on capital and liquidity, to formalise due diligence before accepting new fintech partners, and to commission an independent look-back from September 1, 2022 at all activity in the account of its largest fintech partnership to identify and report suspicious activity. 10

qualification
The order does not name the fintech partners or the largest partnership account.

documentedOn September 17, 2024 the FDIC published a proposed rule that would set heightened reconciliation and recordkeeping standards for certain custodial accounts holding commingled customer funds, citing recordkeeping issues connected with Synapse's commingling of customer funds in custodial accounts, according to a later annual report of another fintech. 11

documentedUnder the consent order, signed for Yotta by board member Adam Moelis on May 8, 2026 and dated May 15, 2026 by Commissioner Khalil Mohseni, Yotta stipulated to an order to desist and refrain from deceptive acts or practices under the California Consumer Financial Protection Law, including representing that cash deposits in Yotta accounts are protected against all risks, and agreed to pay a $1,000,000 penalty: $275,000 within 14 days, $19,565.22 a month for 23 months and a final $275,000 after 24 months. A missed payment would entitle the Commissioner to impose the full penalty of $48,000,000, less any amount paid. Yotta also had to send a notice and May 2024 account information to its California customers with positive balances as of May 17, 2024. 12

sources in this section

  1. Enforcement action page: Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 15 Sep 2025
  2. Complaint, CFPB v. Synapse Financial Technologies, Inc. (Adv. No. 1:25-ap-01052-MB) Consumer Financial Protection Bureau · 21 Aug 2025
  3. Stipulated final judgment and order, CFPB v. Synapse Financial Technologies, Inc. Consumer Financial Protection Bureau · 12 Sep 2025
  4. Civil Penalty Fund allocations Consumer Financial Protection Bureau · 29 May 2026
  5. Consent order, In the Matter of Synapse Payments LLC (Case No. 16-041) New Hampshire Banking Department · Jun 2020
  6. Document register entry: Synapse Payments LLC, 16-041, Consent Order New Hampshire Banking Department · 19 Jun 2020
  7. Notice of intent to refuse to renew small loan license and notice of right to hearing: Synapse Credit LLC Connecticut Department of Banking · 26 Sep 2022
  8. Cease and desist order issued upon consent: Evolve Bancorp, Inc. and Evolve Bank & Trust Board of Governors of the Federal Reserve System and Arkansas State Bank Department · 11 Jun 2024
  9. Media source · src-087 identified by category only · Media
  10. Consent order, In the Matter of Lineage Bank (FDIC-23-0041b) Federal Deposit Insurance Corporation · 30 Jan 2024
  11. Fold Holdings, Inc. annual report on Form 10-K for 2025 U.S. Securities and Exchange Commission (EDGAR) · 2026
  12. Consent order, The Commissioner of Financial Protection and Innovation v. Yotta Technologies, Inc. California Department of Financial Protection and Innovation · 15 May 2026

9Lawsuits and reported investigations involving Synapse

attributedOn September 13, 2024 Yotta Technologies 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, fraud, diversity jurisdiction), accusing the bank of fraud and negligence among other claims; its lawyers alleged grotesque misconduct and described the bank as having a rotten core, and Yotta alleged that Evolve had known of a shortfall long before Synapse's bankruptcy. 1 2 3 4

qualification
Allegations of a plaintiff; the federal court dismissed the case without reaching their merits (see the procedural history).
response
Evolve moved to dismiss; when asked for comment by the business press it shared its motion, which argues that the bank was entitled to the fees it took.
outcome
The court dismissed the case on February 18, 2026, holding that Synapse was a necessary party; Yotta appealed to the Ninth Circuit, whose mandate was entered on the district-court docket on October 6, 2026.

documentedIn the federal case, Yotta voluntarily dismissed its claims against Evolve Bancorp on January 23, 2025. On May 15, 2025 Judge Trina L. Thompson granted Evolve Bank & Trust's motion to dismiss Yotta's claims of fraud, conspiracy, negligence, unfair competition and unjust enrichment, with leave to amend, and ordered Yotta to plead jurisdiction and Synapse's status as a joint tortfeasor, noting that Synapse might be a necessary party under Rule 19. Yotta filed an amended complaint on June 4, 2025; Evolve moved again to dismiss, including for failure to join a required party, and on February 18, 2026 the court granted the motion and closed the case the next day. According to the trade press, the judge ruled that Evolve did not have to face the suit because Synapse was a necessary party. 1 5 3 4

documentedYotta appealed the dismissal to the U.S. Court of Appeals for the Ninth Circuit (No. 26-1535). The Ninth Circuit's mandate was entered on the district-court docket on October 6, 2026; the outcome of the appeal is not visible in the retained docket. 3

attributedOn March 13, 2026 Yotta filed a new lawsuit against Evolve Bank & Trust in California state court, alleging that Evolve stole millions of dollars from Yotta's customers in a Ponzi or Ponzi-like scheme, lied about its controls and capabilities and concealed the deficit with false transaction and balance information, and that Yotta's end users remained deprived of $80 million. Yotta named Synapse as a second defendant only out of an abundance of caution because of the federal ruling, stating that it had no intention of bringing claims against Synapse. 4

qualification
Allegations in a complaint as reported by the trade press; no ruling in the state case appears in the record.

documentedConsumers' putative class actions against the partner banks are consolidated in the U.S. District Court for the District of Colorado under lead case No. 24-cv-03259-DDD-NRN, together with Nos. 24-cv-03261, 24-cv-03262, 24-cv-03509, 25-cv-00075 and 25-cv-03284, against Evolve Bank & Trust and Evolve Bancorp, AMG National Trust Bank and Lineage Bank. The court describes the action as arising from the collapse of Synapse, through which consumer funds were deposited with those banks. On April 16, 2026 Magistrate Judge N. Reid Neureiter granted the plaintiffs' motion to extend the schedule, setting the close of fact and class discovery for January 15, 2027, the class-certification motion deadline for March 17, 2027 and dispositive motions for September 29, 2027. 6

qualification
The case was pending at the evidence cutoff; no finding of liability appears in the record.

attributedIn the Colorado case 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 it received after the bankruptcy, and that it owed the plaintiffs no duty because its contract was with Synapse Brokerage; the plaintiffs dispute the reliability of the data and method. Citing plaintiffs' counsel, the court noted that the case requires tracing deposits in pooled FBO accounts across several banks, involving hundreds of millions of dollars and more than ten terabytes of data, and that neither the Synapse trustee nor any defendant had completed a full reconciliation. 6

qualification
Positions of the parties summarised by the court in a scheduling order; the summary-judgment motion was undecided at the cutoff.
response
The plaintiffs dispute the reliability of the data and method on which AMG relies; the other defendants did not oppose the schedule extension that AMG opposed.
outcome
On April 16, 2026 the court extended the schedule, setting March 17, 2027 as the deadline to move for class certification; the summary-judgment motion was undecided at the evidence cutoff.

documentedAnother putative class action, filed in the U.S. District Court for the Central District of California on November 27, 2024 (No. 2:24-cv-10317), named Evolve Bank & Trust, Evolve Bancorp, Inc. and Lineage Bank. On October 16, 2025 Judge George H. Wu transferred it to the District of Colorado under the first-to-file rule because of the earlier litigation there, leaving undecided the plaintiff's motion to add Synapse Financial Technologies, Synapse Brokerage, Mark Paverman and Jeffrey Stanley as defendants. 7

documentedOn March 5, 2026 a putative class action was filed in the Central District of California (No. 2:26-cv-02385), classified as a racketeering (RICO) case, against Synapse Financial Technologies, Synapse Brokerage, Mark Elliot Paverman, Sankaet Pathak and Jeffrey Alan Stanley; it was assigned to Judge Wu as related to the 2024 case against Evolve. A summons to Pathak was issued on April 7, 2026, and by July 29, 2026 the docket showed no proof of service on him; Paverman acknowledged service on May 4, 2026, Synapse was served through California's secretary of state under an alternative-service order and the clerk entered its default on July 1, 2026. After an order to show cause for lack of prosecution, the court set a status conference for September 17, 2026. 8

qualification
The docket shows the claims' classification but no ruling on their merits; a default entered by the clerk is not a judgment.

documentedIn April 2021 the owner of a house in San Francisco's Twin Peaks neighbourhood, leased from April 2015 as a residence and used as Synapse's office, sued Bryan Keltner, Sankaet Pathak and Synapse in San Francisco Superior Court for breach of contract, fraud and damage to the property, seeking nearly $1 million. On August 30, 2023 the court sustained Pathak's and Synapse's demurrer to the amended complaint with leave to amend; the case was unresolved when Synapse filed for bankruptcy. 9 10

attributedAccording to press reports, a lawsuit filed by three former employees against Synapse and Pathak personally around 2019 alleged harassment and gender and age discrimination, including a claim that Pathak refused to pay the former head of sales while she was on maternity leave; the suit was eventually settled. 10 2

qualification
Reported by the trade and business press; the complaint and settlement terms are not retained, and a settlement is not a finding on the allegations.
response
Pathak dismissed the lawsuit's allegations and critical online employee reviews as cancel culture run amok, according to a 2025 interview.
outcome
The suit was eventually settled; its terms are not in the record.

attributedAccording to a March 2025 business-press report, a court filing in late January 2025 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; prosecutors had subpoenaed Victor Medeiros, Synapse's former corporate controller, and were investigating possible violations including accounting fraud and wire fraud. Another press report said the subpoena was issued in November 2024. 2 11 12

qualification
Press accounts of a court filing that is not retained; Medeiros has not been accused of any wrongdoing, the U.S. Attorney's Office declined to comment, and the record shows no criminal charge.
response
Pathak said in November 2024 that he was not aware of any criminal investigation and had not been contacted by law enforcement, though he had spoken with FINRA, and in March 2025 that prosecutors had not contacted him. The trustee and Judge Barash said repeatedly that they could neither confirm nor deny any referral to law enforcement.

sources in this section

  1. Court record source · src-061 identified by category only · Court record
  2. Media source · src-021 identified by category only · Media
  3. Court record source · src-069 identified by category only · Court record
  4. Media source · src-062 identified by category only · Media
  5. Court record source · src-068 identified by category only · Court record
  6. Court record source · src-070 identified by category only · Court record
  7. Court record source · src-066 identified by category only · Court record
  8. Court record source · src-072 identified by category only · Court record
  9. Court record source · src-064 identified by category only · Court record
  10. Media source · src-063 identified by category only · Media
  11. Media source · src-025 identified by category only · Media
  12. Media source · src-076 identified by category only · Media

10The people behind Synapse: founders, investors, directors and officers

documentedSankaet Pathak founded Synapse in 2014 and was its chief executive until May 2024. He was quoted as chief executive in 2019, signed the bankruptcy petition in that capacity on April 22, 2024, and was described as Synapse's former chief executive in the senators' letter of June 28, 2024 and by the trustee. 1 2 3 4

documentedBryan Keltner is described as Synapse's co-founder: a 2025 business-press report calls him Pathak's co-founder and a fellow University of Memphis alumnus, a 2024 trade-press report says he met Pathak at the university, and a corporate-data profile lists him as co-founder of Synapse since April 2014. 5 6 7

attributedA 2024 trade-press report, based on sources and internal records, says Keltner led Synapse's compliance, at times with the title chief compliance officer, and sat on the board in the early years; that before the Series A he was removed from the board while operations lead Hillary Quirk was given the title of co-founder and joined it; that he stepped back from day-to-day work in late 2017 or early 2018 and the company bought back his shares for a sum in the millions of dollars; and that Synapse later engaged him as a contractor reporting to Pathak from November 2018 to July 2021 and to then chief financial officer Mike Rasic from January to April 2023. 6 8

qualification
Reported from unnamed sources and internal records that are not retained. The report dates the Series A to late 2017, while the company's own announcement is dated September 6, 2018.
response
Keltner confirmed the approximate timing of when he stopped regular work at the company.

attributedAccording to multiple sources cited by a trade newsletter in August 2024, Evolve engaged Keltner in some capacity to help with its Synapse reconciliation. 6

qualification
Reported from unnamed sources; neither Evolve nor Keltner confirmed the engagement.
response
Keltner neither confirmed nor denied working for Evolve, saying only that he was working on his own trading business; Evolve did not respond to repeated requests for comment.

documentedHillary Quirk joined Synapse as head of operations in October 2014, after serving as a program director at Start Co. in Memphis, according to a corporate-data profile; a trade newsletter reported, citing her professional profile, that she stayed at the company until August 2022. She was one of the three directors who signed the board's bankruptcy resolution in April 2024, and was described as a Synapse co-founder. 9 6 10 2

documentedJeffrey Webb, listed as a director and member of Synapse Payments, LLC in its 2015 Form D, gave the same Memphis address as the company, 6745 Lenox Center Ct., Suite 300, which Varsity Spirit gives as its corporate office; a 2024 trade-press report names Jeff Webb, founder of Varsity Brands, as one of the two sources of Synapse's initial $700,000 investment. Webb, who founded Varsity Spirit in 1974, died in March 2026, according to a business-press report of March 20, 2026. 11 12 6 13

qualification
The identification of the Form D director with the Varsity founder rests on the shared name, city and office address and the press report; the Varsity contact page is a current record, not a 2015 one.

documentedDouglas Marchant was a director and member of Synapse Payments, LLC in 2015 and remained on Synapse's three-member board in April 2024; the trade press describes him as a seed-round investor and as a founder of the payments company Concord EFS, later acquired by First Data. A Memphis business-network profile of a Douglas J. Marchant describes him as a founder of Concord EFS and of Unified Health Services. 10 2 14 13

qualification
The business-network profile does not mention Synapse; the identification rests on name, city and the Concord EFS background.

documentedOn September 6, 2018 Synapse announced a $17 million Series A financing led by Trinity Ventures and Core Innovation Capital, with contributions from other investors; Schwark Satyavolu of Trinity Ventures and Arjan Schütte of Core Innovation Capital joined its board. 8

documentedIn June 2019 Synapse raised $33 million in a Series B round led by Andreessen Horowitz with the existing investors Trinity Ventures and Core Innovation Capital, bringing its total funding to $50 million; Angela Strange, a general partner at Andreessen Horowitz, joined the board as part of the investment. A corporate-data aggregator puts total funding at $50.7 million over three rounds, the first on April 1, 2015 and the latest the Series B of June 6, 2019. 1 4

documentedAccording to Pathak, Synapse's board at various times included Angela Strange of Andreessen Horowitz, Schwark Satyavolu of Trinity Ventures and Arjan Schütte of Core Innovation Capital. By the time of the bankruptcy resolution in April 2024 the board consisted of Pathak, Doug Marchant and Hillary Quirk, the directors who also approved Pathak's loans from the company. 10 2

documentedStrange has been a general partner at Andreessen Horowitz since 2018 and a partner there from November 2014; Satyavolu is a venture partner at Trinity Ventures and a co-founder of the fintech companies Yodlee and Truaxis; Schütte is founder and managing partner of Core Innovation Capital and a managing member of the general partner of its third fund, Core Innovation Capital III, L.P. None of their current profile pages lists Synapse. 15 16 17 18 19

attributedPathak has said that in November 2022 Synapse had lined up a Series C round of about $100 million and was pursuing a bank charter of its own, and stated in court filings that the round was vetoed by certain investor directors. 5

qualification
Pathak's own account; the investors' side is not on the record.
response
Andreessen Horowitz, Trinity Ventures and Core Innovation Capital declined to comment or did not respond to a 2025 business-press request.

attributedPathak acknowledged in a November 2024 interview that he took two loans from Synapse, in late 2023 and early 2024, totalling $320,000, approved by a board then consisting of himself, a seed investor and a co-founder, identified from bankruptcy filings as Doug Marchant and Hillary Quirk. 10

qualification
Pathak's own description; the loan documents and board approval are not retained.
response
Pathak declined to explain the purpose of the loans beyond saying he had good reasons that would become obvious relatively soon.

documentedTracey Guerin stated in a sworn declaration of May 23, 2024 that she had been general counsel of Synapse Financial Technologies since June 2022 and associate general counsel from June 14, 2018 until June 2022. 20

documentedMichael Rasic was listed as an officer of Synapse Financial Technologies and of Synapse Credit in Washington's registry; in September 2022 Connecticut addressed Synapse Credit's licence notice to him as its chief financial officer and chief business officer, and a trade newsletter refers to him as Synapse's chief financial officer in early 2023. 21 22

documentedVictor Medeiros is described in press reports as Synapse's former corporate controller and as a former senior director in its finance department. 5

documentedAll remaining Synapse employees were terminated as of May 24, 2024, after which the company was run by the Chapter 11 trustee. 23

documentedJelena McWilliams, the Chapter 11 trustee, was sworn in as the 21st chair of the FDIC on June 5, 2018 and led the agency until 2021. She had earlier been executive vice president, chief legal officer and corporate secretary of Fifth Third Bank, chief counsel of the Senate Banking Committee and an attorney at the Federal Reserve Board, and had practised corporate and securities law at Morrison & Foerster and Hogan & Hartson. During the trusteeship she was a partner at Cravath, Swaine & Moore, which represented her as trustee; in January 2026 the fintech Plaid hired her as president of corporate and external affairs. 24 25 26 27

sources in this section

  1. Media source · src-008 identified by category only · Media
  2. Court record source · src-022 identified by category only · Court record
  3. Senators' letter to Sankaet Pathak of June 28, 2024 Office of Senator Tammy Baldwin, U.S. Senate · 28 Jun 2024
  4. Media source · src-012 identified by category only · Media
  5. Media source · src-021 identified by category only · Media
  6. Media source · src-063 identified by category only · Media
  7. Other source · src-047 identified by category only · Other
  8. Company statement source · src-071 identified by category only · Company statement
  9. Other source · src-043 identified by category only · Other
  10. Media source · src-025 identified by category only · Media
  11. Company statement source · src-096 identified by category only · Company statement
  12. Media source · src-097 identified by category only · Media
  13. Form D notice of exempt offering: Synapse Payments, LLC U.S. Securities and Exchange Commission (EDGAR) · 1 Apr 2015
  14. Other source · src-045 identified by category only · Other
  15. Other source · src-026 identified by category only · Other
  16. Company statement source · src-014 identified by category only · Company statement
  17. Company statement source · src-044 identified by category only · Company statement
  18. Company statement source · src-048 identified by category only · Company statement
  19. Form D notice of exempt offering: Core Innovation Capital III, L.P. U.S. Securities and Exchange Commission (EDGAR) · 5 Apr 2019
  20. Court record source · src-034 identified by category only · Court record
  21. Corporate registry source · src-005 identified by category only · Corporate registry
  22. Notice of intent to refuse to renew small loan license and notice of right to hearing: Synapse Credit LLC Connecticut Department of Banking · 26 Sep 2022
  23. Regulatory record source · src-009 identified by category only · Regulatory record
  24. Official biography: Jelena McWilliams Federal Deposit Insurance Corporation
  25. Speaker biography: Jelena McWilliams Single Resolution Board (European Union) · 8 Oct 2020
  26. Media source · src-067 identified by category only · Media
  27. Court record source · src-001 identified by category only · Court record

11Sankaet Pathak

documentedWhile still chief executive of Synapse, Pathak co-founded a humanoid robotics company, Foundation, in April 2024 with Arjun Sethi, chief executive of the venture firm Tribe Capital, and Mike LeBlanc, a co-founder of Cobalt Robotics, according to the company's fundraising pitch as reported by the business press. A private-market data provider lists Foundation Robotics Labs of San Francisco, founded by the three in 2024, with an $11 million Series A-1 round on August 22, 2024 at a $73.33 million valuation (Tribe Capital) and a $187 million Series A on August 19, 2025 at a $1.32 billion valuation. Florida's corporate registry lists Foundation Future Industries, Inc., a Delaware corporation registered in Florida on April 22, 2025 with a principal address at 617 Bryant Street, San Francisco, and Sankaet Pathak as its president. In January 2026 a technology newsletter, citing two sources, reported that Foundation Future was seeking up to $500 million at a valuation of more than $3 billion, and in March 2026 a news magazine described Pathak as Foundation's co-founder and chief executive and the company as developing humanoid robots, including for military use. 1 2 3 4 5

qualification
The record does not establish whether Foundation Robotics Labs and Foundation Future Industries, Inc. are the same legal entity; the press uses both names for the company co-founded by Pathak, Sethi and LeBlanc. The funding figures come from a private-market data provider and a newsletter's sources, not from company filings.

attributedIn June 2024 a business-press report, based on fundraising documents, said Foundation Robotics Labs was seeking the last $1 million of an $11 million seed round with a pitch claiming that General Motors had committed to invest alongside Tribe Capital, was set to become its first customer with a targeted $300 million purchase order and had given it access to its factories, including a plant in Mexico, to collect training data. GM said it had never invested in Foundation Robotics, had no plans to do so and had never had an agreement of any kind with the company, calling any claims to the contrary fabricated; co-founder Mike LeBlanc confirmed GM's points and said he was embarrassed that marketing materials overstating the relationship existed. 1 6 4

qualification
Reported from fundraising documents obtained by the business press; the pitch itself is not retained.
response
Tribe Capital and Sethi declined to comment and Pathak did not respond at the time. In November 2024 Pathak told a trade newsletter that the reporter was highly unethical and alleged that the reporter had contacted an auto-industry union leader rather than GM, leading the union leader to threaten a strike if GM did not pull out of the deal.
outcome
A private-market data provider lists an $11 million Series A-1 round of August 22, 2024 with Tribe Capital as its investor; no General Motors investment appears in the record.

sources in this section

  1. Media source · src-027 identified by category only · Media
  2. Florida corporation record: Foundation Future Industries, Inc. (F25000002389) Florida Department of State, Division of Corporations · 1 May 2026
  3. Media source · src-056 identified by category only · Media
  4. Other source · src-078 identified by category only · Other
  5. Media source · src-085 identified by category only · Media
  6. Media source · src-025 identified by category only · Media

12Evolve Bank & Trust

documentedEvolve Bank & Trust of West Memphis, Arkansas, is a state-chartered bank that is a member of the Federal Reserve System; it is owned and controlled by the registered bank holding company Evolve Bancorp, Inc., and both are supervised by the Federal Reserve Board and the Arkansas State Bank Department. Through its Open Banking Division the bank offered deposit accounts and payment processing to fintech partners, which in turn offered financial products to end users. The FFIEC's National Information Center lists the bank (RSSD ID 592448, FDIC certificate 1299) as an active state member bank engaged in commercial banking and Evolve Bancorp (RSSD ID 1142411) as a bank holding company, both at 301 Shoppingway Boulevard, West Memphis. 1 2 3

documentedThe Federal Reserve's order of June 11, 2024 was addressed to Scott Stafford as president and chief executive officer of Evolve Bank & Trust and to B. Scot Lenoir as chairman of the board of Evolve Bancorp and of the bank. Evolve's 2023 investor kit describes Lenoir as the founder and chief executive of Evolve Bancorp, who founded Evolve Bank & Trust in 2004 after serving as chief executive and president of First Mercantile Trust Company, which was sold in 2000, and W. Scott Stafford as president and chief executive of the bank, formerly a senior vice president of National Bank of Commerce and an investment banker with Duncan-Williams, Inc. A financial-data profile lists Lenoir as founder in 2004 and chairman, president and chief executive of Evolve Bancorp and of Evolve Financial Group, Inc., and as a former chairman of Evolve Bank & Trust. 1 4 5

qualification
Titles as stated at the dates of each source; the record does not give a complete management history.

documentedIn its parent-only FR Y-9SP reports to the Federal Reserve, Evolve Bancorp reported net income of about $7.87 million for 2024, including $8.72 million of income from its bank subsidiary, and a net loss of about $7.39 million for 2025, including a $3.02 million loss attributed to the bank subsidiary. At the end of 2025 the parent's total assets were about $165 million, its long-term borrowings $51.1 million and its equity capital $107.3 million, against $114.1 million of equity a year earlier; the group's total consolidated assets fell from about $1.81 billion at the end of 2024 to about $1.29 billion at the end of 2025. Both reports name KPMG of Atlanta as external auditor, record a full-scope independent audit and were signed by chief financial officer Mark Mosteller. A business-press report in October 2025 said Evolve Bank & Trust had lost $8.76 million in the first six months of 2025 while keeping its focus on banking-as-a-service. 6 7 8

qualification
FR Y-9SP amounts are reported in thousands of dollars and rounded here; the parent-only schedule does not show the bank's own statements.

sources in this section

  1. Cease and desist order issued upon consent: Evolve Bancorp, Inc. and Evolve Bank & Trust Board of Governors of the Federal Reserve System and Arkansas State Bank Department · 11 Jun 2024
  2. Institution profile: Evolve Bank & Trust (RSSD 592448) FFIEC National Information Center (Federal Reserve)
  3. Institution profile: Evolve Bancorp, Inc (RSSD 1142411) FFIEC National Information Center (Federal Reserve)
  4. Company statement source · src-046 identified by category only · Company statement
  5. Other source · src-075 identified by category only · Other
  6. FR Y-9SP parent-only report of Evolve Bancorp, Inc. for December 31, 2025 FFIEC National Information Center (Federal Reserve) · 13 Feb 2026
  7. FR Y-9SP parent-only report of Evolve Bancorp, Inc. for December 31, 2024 FFIEC National Information Center (Federal Reserve) · 12 Feb 2025
  8. Media source · src-083 identified by category only · Media

13Yotta Technologies

documentedYotta Technologies, Inc. is a Delaware corporation. California's DFPI describes it as having a business address in San Francisco and the website withyotta.com, and Adam Moelis as its co-founder, former chief executive and a member of its board; it offered high-interest personal savings accounts to California consumers without registering with the California Secretary of State. A copy of New York's corporate registry gives a foreign incorporation date of October 18, 2019 and registration in New York as a foreign business corporation from March 10, 2020 (DOS ID 5724855); its 2022 biennial statement was filed by Adam Moelis, and a filing of March 1, 2026 names Ben Doyle as chief executive officer. 1 2

documentedYotta, which offered sweepstakes games and prizes to people who opened savings accounts with it, signed a contract with Synapse on February 13, 2020 that let it use Synapse's software to interface with Evolve; the federal court recorded that Evolve and Synapse worked together to service Yotta's customers, that Evolve's systems processed certain transactions while Synapse handled others involving funds held with Evolve, and that Yotta and Evolve had no contract with each other. Yotta's disclosures stated that banking services were provided by Evolve Bank & Trust and Synapse Brokerage's program banks, that its debit card was issued by Evolve and that lending services were offered through Synapse Credit LLC. 3 4 5

attributedCalifornia's DFPI found that from May 2020 Yotta told about 18,000 California customers that their deposits were safe, FDIC insured and that they could not lose their money, and that around October 11, 2023 it migrated savings accounts to Synapse Brokerage, which did not provide FDIC protection, while account holders kept their Evolve routing and account numbers. According to the DFPI, Yotta did so despite serious internal concerns about Synapse: its chief executive, Adam Moelis, wrote on the day of the migration that he did not trust Sankaet Pathak, and its management believed that Synapse constantly lied and overpromised. After Synapse's bankruptcy filing on April 22, 2024 at least 18,155 California consumers with Yotta accounts lost access to at least $28 million, and those who sought FDIC insurance found that it did not cover their losses. 5 1

qualification
Findings of the California regulator recited in a consent order; Yotta waived a hearing, and the order provides that its subject matter is deemed admitted only for a future licence application or for enforcement of the order.
response
Yotta waived its rights to a hearing and to any appeal of the desist-and-refrain order and stipulated to its issuance.
outcome
Resolved by the consent order dated May 15, 2026, with a $1,000,000 penalty and a desist-and-refrain order.

attributedAs summarised by the federal court, Yotta's complaint alleges that Evolve suspended interest payments to Yotta in September 2023 and, in answer to its inquiries on September 25 and October 3, 2023, said it was addressing some contractual issues with Synapse while assuring Yotta that the matter was being handled and customers would be protected. The written assurances it cites came from Hank Word, Evolve's president of open banking (September 25, 2023), from Scot Lenoir (October 3, 2023), who added that Yotta could transition to another bank, and from Evolve's outside counsel (November 2, 2023), who described a contractual disagreement between Evolve and Synapse that could plausibly be resolved within weeks. The complaint alleges that Evolve suspended Yotta customers' access to all funds on May 11, 2024 and later acknowledged that a substantial amount of customer money was missing, a shortfall of tens of millions of dollars. 3

qualification
Allegations of the plaintiff as recited by the court in a ruling on a motion to dismiss; the federal case was later dismissed without a ruling on their merits.

attributedYotta told its customers that on May 7, 2024 it was notified that Lineage Bank had halted ACH processing for all Synapse Brokerage accounts and that Evolve would begin processing ACH transactions on Synapse Brokerage's behalf, and that on the evening of May 11 Evolve notified it that it had never agreed to take on ACH processing and would halt all payment processing it was involved in with immediate effect, leaving Synapse Brokerage without an ACH processor and causing card transactions to fail. 4 6 7

qualification
Yotta's account on its customer status page.
response
Evolve told the bankruptcy court on May 13, 2024 that it had been denied access to Synapse's computer systems and had been forced to freeze end-user accounts.
outcome
According to FINRA, Synapse Brokerage customers could not withdraw any money from May 11, 2024, after the first deposit bank refused to process payments for the brokerage.

attributedAt the hearing of May 24, 2024 an attorney for Yotta called the ledger discrepancies substantial: according to a press report, Synapse had stated that $111 million of Yotta funds were held at Evolve, while Evolve put the figure at only $80 million. 8

qualification
Positions of the parties as reported from the hearing; the figures were later the subject of the banks' reconciliations.

documentedThe federal court's order of May 15, 2025 referred to two other cases in the Southern District of New York: one against Yotta Technologies and Evolve Bank and Trust (No. 24-cv-5535) and one against Yotta Technologies (No. 22-cv-8569). 3

qualification
The order cites the cases without describing them; their claims and outcomes are not in the record.

sources in this section

  1. Consent order, The Commissioner of Financial Protection and Innovation v. Yotta Technologies, Inc. California Department of Financial Protection and Innovation · 15 May 2026
  2. Corporate registry source · src-037 identified by category only · Corporate registry
  3. Court record source · src-068 identified by category only · Court record
  4. Company statement source · src-051 identified by category only · Company statement
  5. DFPI press release on the $1 million settlement with Yotta Technologies California Department of Financial Protection and Innovation · May 2026
  6. Court record source · src-017 identified by category only · Court record
  7. Regulatory record source · src-009 identified by category only · Regulatory record
  8. Media source · src-093 identified by category only · Media

cite this dossier

DossierTwist, “Synapse Financial Technologies: the collapse of a banking-as-a-service provider”, dt.022, 17 October 2026, https://dossiertwist.com/dossiers/synapse-financial-technologies/

Free to read, cite and republish with credit under CC BY 4.0: credit “DossierTwist” and link to the dossier.

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We listen to all sides: responses are shown next to the claims they answer. To send a correction or a reply, write to dossiertwist@proton.me.