Earlier this year, BaaS firm Synapse collapsed amidst a dispute with banking partner Evolve Bank & Trust. This left the customers of several Synapse clients - including Copper and Yotta - unable to access their funds. This is because, Synapse and other non-bank companies, generally do not place their customers’ funds in individual accounts at banks. Instead, depositing these funds together into a single custodial account that may hold funds of many thousands of consumers and businesses. This can leave the bank unable to easily and quickly know or be able to determine the individual owners of funds within that custodial account. Under the new proposed Federal Deposit Insurance Corporation (FDIC) rule, banks holding certain custodial accounts would be required to take steps to ensure accurate account records are maintained in order to determine the individual owner of the funds, including a requirement to reconcile the account for each individual owner on a daily basis. In addition, the banks’ primary federal supervisor would have oversight to review for compliance with this rule and enforcement authority. Martin Gruenberg, FDIC chairman, say the plan "is an important step to ensure that banks know the actual owner of deposits placed in a bank by a third party such as Synapse, whether the deposit has actually been placed in the banks, and that the banks are able to provide the depositor their funds even if the third party fails".