Synapse functioned as a middleware provider between banks and fintechs. Synapse was a pioneer in what came to be known as “banking-as-a-service” (BaaS). In this role, Synapse opened accounts on behalf of approximately 100 fintech companies (and millions of end users) at four different partner banks, whose primary federal regulator was either the Federal Reserve, FDIC, or Office of the Comptroller of the Currency (OCC), and whose state regulators included Arkansas, Tennessee, Nebraska, and Colorado. Synapse managed ledgering for these accounts, tracking all transaction activity and account balances. It is our understanding that the partner banks could access a portal that provided snapshots of how much each end user was owed, but not which partner bank held those funds. None of the partner banks maintained a copy of Synapse’s account ledger. As a result, the partner banks and fintechs were all reliant on Synapse to determine how much each customer was owed at all times. On April 22, 2024, Synapse filed for Chapter 11 bankruptcy. On May 11, the partner banks lost access to the records maintained by Synapse and were unable to determine which end-users rightfully should be able to withdraw their funds. As a result, they froze access to a portion of the funds for an extended period while they attempted to determine ownership.