I think the FDIC insurance is per account at a bank with a banking charter. Fintechs are typically given one account by a real bank and so funds are commingled but also it is a single account so only 85k insuran ce even though the account might have 1000s customer funds commingled.

That's batshit insane.

This is not true for fiduciary accounts, which are covered per principal. So FDIC coverage should extend to all customers if the account was properly declared.

This isn’t accurate. A fintech’s own money (as opposed to customer funds) may have low insurance. But if set up properly, those customer funds can have pass through FDIC insurance. See https://www.fdic.gov/financial-institution-employees-guide-d...

However this apparently doesn’t protect you from the failure of the third party, which is what is unexpected. If you look at this bulletin the FDIC put out after the Synapse incident, they’re basically claiming they aren’t stepping in because a bank hasn’t failed. A fintech that isn’t the bank, but has records of what’s at the bank, failed.

https://www.fdic.gov/consumer-resource-center/2024-06/bankin...

Personally, I find the explanation to be pretty weak - what does pass through insurance even mean then? Does every fintech startup need to also directly be a bank - if so that’s a huge barrier to entry and basically gifts incumbents with regulatory capture. If the money is in an FDIC protected account, it should be safe. It does not make sense to me that they would step in for Silicon Valley Bank’s failure, but not in this situation.

One weird part of the situation is that it seems the underlying bank does not have records about each customer and their numbers. To me that seems negligent on the part of the underlying bank. Surely they knew about this arrangement of pass through insurance and the need to protect funds. They should have maintained separate accounts for each client of the third party service. Regardless of negligence it seems the FDIC is trying to make this record keeping a requirement: https://www.fdic.gov/news/press-releases/2024/fdic-proposes-...

I mean the FDIC is an insurance program, if it extends insurance to entities that haven't bought in their risk profile changes.

I agree. But I think the issue is that the FDIC is providing pass through insurance but also now clarifying in an unexpected way, that only failures of the underlying bank trigger insurance coverage. It may be technically right but it has many implications that are negative. To the everyday person it’s also perverse that highly connected rich people, like VCs tied to SVB, can get their money protected beyond any insurance limit based on their power, but poor individuals just have zero influence.

That's not true in the US generally (FDIC "pass-through insurance" is a thing).

The problem here wasn't a lack of FDIC insurance, but rather a lack of record keeping that allowed attribution of insured balances to individual beneficiary account holders.

The fact that any bank would advertise "FDIC insured" is silly, as it conditions potential customers to look to the banks for this information. It would be better if folks were conditioned to consult only the FDIC themselves for this information.

It serves the same purpose as asking customers "are you a terrorist" -- it creates an easily prosecutable offence.

Could you expand on why is it easily prosecutable?

I sense that it has something to do with lying in documents.

But hypothetically: if I write “no”. Proof of lying requires proof of terrorism. (At which point you did all the job of proving terorism, despite the document)

If you ask it online then I guess it counts as wire fraud which may be easier to prosecute.

Is terrorism not already an easily prosecutable offense?

It should be a protected term in advertising. As soon as you use it, you surrender yourself to FDIC auditors.

There's generally nothing stopping scammers from lying in ads. Enforcement is only done afterwards.

The whole point of banking that people have forgotten is trust.

Large banks have gone to great lengths to teach people that banks can never be trusted

I trust them a whole lot more than any random fintech company. At least with traditional banks, there is some amount of protection available.

Put differently:

Less than zero: trust to place in random fintech company

Zero: trust to place in random bank

Very low value: trust to place in a carefully selected bank

Moderate value: trust to place in FDIC