Data · Sponsor bank register
We checked 15 US sponsor banks against federal enforcement dockets. Nine carry a record.
Public sponsor-bank lists drift in three directions: they keep banks that no longer exist, they keep enforcement flags regulators have since lifted, and they miss orders issued after they were published. Boldrails queried the FDIC, OCC and Federal Reserve directly on 2 August 2026 and recorded the docket number and date for every one of 15 US banks.
- 15 banks checked
- 9 with a record
- 3 regulator dockets
- Verified 2 Aug 2026
Onboarding in 3 to 14 days, depending on your case
Last updated: 2 August 2026
The register at a glance
15
US banks checked against federal enforcement dockets
Boldrails register, 2 August 2026
13
Enforcement records pulled from the issuing regulator's own docket
FDIC ED&O, OCC EASearch, Federal Reserve
3
Directions in which public sponsor-bank lists drift from the record
Boldrails analysis, 2 August 2026
1
Bank still listed as an available sponsor that the Federal Reserve says no longer functions as a bank
Federal Reserve, 26 July 2024
In short
Public sponsor-bank lists drift in three directions at once. They keep banks that no longer exist, they keep enforcement flags regulators have since lifted, and they miss orders issued after the list was published. Boldrails queried the FDIC, OCC and Federal Reserve enforcement systems directly on 2 August 2026 and wrote down what came back for 15 US banks, with the docket number and date on every row. Nine of the 15 banks below carry a published federal enforcement record. Six returned no record in the two dockets we queried. Every status is a dated snapshot, not an open-ended claim.
By Claude Igrow. Last updated: 2 August 2026.
Definitions
What is a sponsor bank, and what is an FBO account?
A sponsor bank is a chartered bank that lets a non-bank company offer regulated financial services under the bank's charter. An FBO account, short for for benefit of, is the pooled account that bank holds those end-user funds in. The bank owns the banking relationship, and end users keep beneficial ownership of the money.
The two go together. A sponsor bank gives a fintech access to Federal Reserve payment rails and, separately, to card-network BINs through BIN sponsorship. The FBO account is the structure the money actually sits in. A subledger is what makes each end user's balance traceable inside the pool.
A bank charter is what makes any of this possible. Only a chartered institution can hold insured deposits and reach the payment rails directly, which is why the charter type on each row below also tells you which regulator supervises that bank. Where a technology platform sits between the fintech and the bank, the arrangement is usually sold as banking as a service, but the charter, and the regulatory exposure that comes with it, still belongs to the bank.
Three other things get called sponsorship, and none of them is this. Sports sponsorship is a bank paying to put its name on a team or a tournament. Visa sponsorship, in the H1B sense, is a bank employing a foreign worker. And in India, a sponsor bank is the commercial bank that sponsors a Regional Rural Bank, which is an ownership structure rather than a fintech arrangement.
What this means
A sponsor bank enables deposit holding and card issuing. An acquiring bank enables merchant card acceptance. One institution can do both, but these are different functions on different contracts, and a glossary that treats them as synonyms will send you to the wrong counterparty.
The register
Which sponsor banks have an enforcement record? The register
Of 15 US banks that appear on public sponsor-bank lists, nine have a published federal enforcement record and six returned no record in the FDIC and OCC dockets. Four of the nine records are terminated or wound down. One bank, Lineage Bank, took a second FDIC consent order on 24 June 2026. All statuses are as of 2 August 2026.
The records are not all the same kind of record. The Federal Reserve's enforcement action against Evolve Bank & Trust, dated 14 June 2024, found that the bank engaged in unsafe and unsound banking practices by failing to have in place an effective risk management framework for those partnerships. Others in the register go to BSA and AML programme deficiencies, capital, or consumer compliance. That is why every row carries its docket number. The scope sits in the order itself, and you can read it without asking anyone's permission.
Table 1. Sponsor bank enforcement register, as of 2 August 2026
| Bank | Charter and regulator | Cert / charter no. | Enforcement status as of 2026-08-02 | Docket | Issued | Terminated |
|---|---|---|---|---|---|---|
| Evolve Bank & Trust | State member bank / Federal Reserve | Not recorded in this check | Active enforcement action | Press release enforcement20240614a | 2024-06-14 | Not stated |
| Silvergate Bank | Federal Reserve | Not recorded in this check | Liquidation and wind-down complete; no longer functions as a bank | Press release enforcement20240726a | 2024-07-26 | Not applicable |
| Blue Ridge Bank, N.A. | National bank / OCC | Charter 23903 | Terminated cease and desist order | AA-ENF-2023-68 | 2024-01-24 | 2025-11-13 (AA-ENF-2025-58) |
| Lineage Bank | FDIC-supervised | Cert 6100 | Active, second consent order | FDIC-26-0028b | 2026-06-24 | None |
| Thread Bank | FDIC-supervised | Cert 9499 | Terminated consent order | FDIC-24-0022b | 2024-05-21 | 2025-12-22 |
| Piermont Bank | FDIC-supervised | Cert 59154 | Active consent order | FDIC-23-0038b | 2024-02-27 | None |
| Sutton Bank | FDIC-supervised | Cert 5962 | Active consent order | FDIC-23-0110b | 2024-02-01 | None |
| Cross River Bank | FDIC-supervised | Cert 58410 | Active consent order | FDIC-22-0040b | 2023-03-08 | None |
| The Bancorp Bank | FDIC-supervised | Cert 35444 | No active FDIC order; earlier orders all terminated | Multiple, 2012 to 2019 | Various | All terminated by 2020-11-17 |
| Column N.A. | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
| WebBank | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
| Pathward | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
| Lead Bank | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
| Grasshopper Bank | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
| Stride Bank | Not established by this check | Not established by this check | No published FDIC or OCC enforcement order found as of 2026-08-021 | None found | None found | None found |
¹ These six rows record an absence in two specific dockets, the FDIC's and the OCC's. They are not a statement that the bank has never been subject to enforcement, and they are not a clean bill of health. The Federal Reserve supervises state member banks and publishes separately, and state regulators publish separately again. Neither was queried for these six rows. See the method section below.
Four institutions in the register carry earlier orders that are already closed, or a second order alongside the one in Table 1. We list those separately, because a closed order read as a live one is exactly the mistake this register exists to stop.
Table 2. Earlier and additional orders on the same institutions
| Bank | Action | Docket | Issued | Terminated |
|---|---|---|---|---|
| Blue Ridge Bank, N.A. | Formal Agreement | 2022-043 | 2022-08-29 | 2024-01-24 (AA-ENF-2024-13) |
| Lineage Bank | Consent Order, first | FDIC-23-0041b | 2024-01-30 | None. Still active |
| Sutton Bank | Consent Order | FDIC-15-0074b | 2015-07-27 | 2017-11-01 |
| Cross River Bank | Consent Order, civil money penalty of $641,750, and restitution | FDIC-17-0121b, -0123b, -0122k | 2018-03-28 | 2021-01-19 |
Two dates in these tables are commonly reported wrong. Lineage Bank's first consent order is dated 2024-01-30 in the FDIC's own record. Secondary sources say 29 January, and they are wrong. Blue Ridge Bank's cease and desist order ended on 2025-11-13, so any list still flagging Blue Ridge as under an OCC order is out of date by more than eight months.
What this means for a founder choosing a sponsor bank
An enforcement record is a fact about a bank, not a verdict on it. Four of the nine records here are closed. That means four banks a 2024-vintage list tells you to avoid are no longer under the order that list was reacting to. So the useful question is not does this bank have a consent order. It is what does the order restrict, and is it still in force. Both answers sit in the docket, and both are free to read.
The pattern
Why the public sponsor-bank lists are wrong, in three directions
Public sponsor-bank lists go stale in three separate ways, which is what makes them worse than merely old. Lists keep banks that have wound down. They keep enforcement flags regulators have since lifted. And they miss orders issued after the list was written. You cannot assume the error runs in your favour, and you cannot assume it runs against you.
Direction one: still listed, no longer a bank. As of 2 August 2026, thefintechmap.com still lists Silvergate Bank in its banks directory. The Federal Reserve stated on 26 July 2024 that Silvergate has completed its liquidation and wind-down plan, has paid back all deposits to its customers, and no longer functions as a bank. Two years separate the statement from the listing.
Direction two: listed as troubled, order already terminated. Thread Bank's FDIC consent order was terminated on 22 December 2025. Blue Ridge Bank's OCC cease and desist order was terminated on 13 November 2025. Any list built from 2024 enforcement reporting still marks both as under order. That error costs a founder two viable banks.
Direction three: listed as clear, enforced again. Lineage Bank took a second FDIC consent order, docket FDIC-26-0028b, on 24 June 2026. No list or tracker in the corpus we reviewed carries it.
The staleness is structural, not careless. Velmie's guide to partner banks used by US fintechs is titled for 2026, and its own conclusion reads "As we look ahead to 2024." Lithic's bank-partners post ranks first for the list query and contains no list; its sponsor-bank section defers to a third-party spreadsheet it describes as a couple of years old. Bankingembedded.com publishes a bank directory with no status column at all. Alloy's guide is the sharpest of the set. It tells the reader to go and read the consent orders, and then provides none.
The closest attempt is fintechspecs.com. Its sponsor-bank post dated 20 June 2026 carries a real nine-bank table and names regulatory actions inline, but there is no dedicated status column, no per-row last-verified date, and no primary regulator citations. So this register is not the only table in the category. It is the only one we know of with a dated, primary-sourced enforcement status on every row.
What this means
These are useful documents that went stale. A directory written in 2024 was accurate in 2024. What breaks it is that sponsor-bank enforcement status has a half-life measured in months, and almost nobody goes back to re-query the docket. Read any undated list as a snapshot of the year it was written, then check the current status yourself.
The limit of public data
Why no list can tell you which bank will accept you
Not one bank in this register publishes an acceptance policy, and nobody in the category says so out loud. There is no page at any of these 15 banks that names the verticals they underwrite, the minimum volume they want, or whether they take pre-revenue companies. So the question every founder is actually asking, who will take me, cannot be answered from public data at all.
What the public record supports is the elimination half of the decision. You can establish, from primary sources, that a bank has wound down, that it is under a live order, or that an order against it has been lifted. That turns a long list into a short one. It does not tell you the short list will say yes.
The rest of the work is yours to do directly.
Do this directly
- 1.Start with your own profile: vertical, expected monthly volume, average transaction size, cross-border exposure, and whether you need deposit sponsorship, BIN sponsorship, or both. Most rejections come down to a mismatch on one of those five, and most of them are visible long before the first call.
- 2.Approach banks in parallel, not in sequence. Sponsor-bank diligence runs for months, and a serial process means one no restarts the clock.
- 3.Read the orders. A consent order is a public document. Some restrict new fintech partnerships specifically, which tells you the bank cannot onboard you right now. Others go to capital or consumer compliance and say nothing about your programme at all. The scope is in the text.
- 4.Ask about redundancy early. An exclusivity clause blocks you from holding a second sponsor, which is the difference between a bank exit being an inconvenience and being an outage.
Boldrails covers the operator's side of this in our guide to high-risk business bank accounts.
Diligence runs both ways
What sponsor banks look for, and what to ask them
The bank is underwriting you, and you are underwriting the bank. Most founders prepare hard for the first half and improvise the second.
What the bank underwrites in you
Ledger reconciliation ownership comes first, and it sinks more applications than anything else on the list. The bank needs to know who maintains the subledger behind the FBO account, how often it reconciles to the pooled balance, and what happens when it does not. Regulators have named reconciliation failures repeatedly in bank-fintech enforcement. After that comes your BSA/AML programme: KYC and CIP rules, who files SARs, how transaction monitoring escalates. Then third-party risk management, which the FDIC, Federal Reserve and OCC addressed together in their July 2024 statement on third-party deposit arrangements. Expect to produce a vendor management policy, a documented FBO structure, and named accountable people.
What you should underwrite in the bank
Ask whether BIN sponsorship is direct from the bank or runs through an intermediary, because that decides who you can actually call when a card programme breaks. Get the oversight cadence in concrete terms: how often they review your programme, what triggers an unscheduled review, and what evidence they will want each time. Escalation SLAs belong in writing, with names and response times against them, not a shared inbox. And find out how many fintech programmes they run, whether they have exited any, and why.
Then ask about enforcement directly. Consent orders are public and reviewable, so a bank that has one should be able to walk you through its scope and remediation status without hesitating. Not every order is disqualifying. Four of the nine records in this register are already closed. What matters is whether the order restricts new partnerships, how far into remediation the bank is, and whether the answer you get matches the docket.
If your business also needs an operating account alongside the sponsorship, our holding and settlement accounts and merchant accounts for high-risk businesses cover that side.
Pricing shape
What BIN sponsorship costs and how it is structured
BIN sponsorship is priced as a structure, not a rate card. Expect pre-launch milestone fees, diligence and setup fees, marketing-review and compliance fees, ongoing basis points on volume, and a reserve held against transaction volume, commonly three to four days' worth. Actual amounts are quote-gated across the whole category.
The line items stay consistent even where the numbers do not. Pre-launch fees typically trigger at two points, at term sheet and again at launch, and some agreements add a late fee if go-to-market slips. Ongoing pricing is usually described as a few basis points on volume, though the model underneath it varies: an interchange take rate, a per-account-per-month charge, or a fee on deposits originated. Contract lengths of one, two, three and five years are all in use. Exclusivity clauses and volume minimums are the negotiable levers, and they are the two terms worth pushing hardest on, because exclusivity is what stops you holding a backup sponsor.
A caveat on the numbers, stated honestly
Every pricing item in this section comes from a single public vendor source. None of it is cross-verified, because per-bank BIN sponsorship pricing is not published anywhere in the category. We are describing the shape of the deal, not quoting a market rate. Anyone who gives you a precise industry-average figure for BIN sponsorship is estimating.
Boldrails does not publish per-programme pricing on this page either, for the same reason: it is scoped to volume, vertical and corridor. If you want a number for your case, tell us your volumes and vertical and we will price it.
Beyond the US
Sponsor banks and BIN sponsorship outside the US
The sponsor-bank model, under that name, is a US construct. It exists because a US fintech needs a chartered bank to reach Federal Reserve payment rails and to hold insured deposits. Elsewhere the same function sits with e-money institutions and payment institutions authorised in their own right, under regimes such as the UK's and the EU's. Different legal shape, different paperwork.
Search demand outside the US reflects that. Across the United Kingdom, Canada, Germany, Australia, Brazil, Nigeria, the Philippines and Vietnam, sponsor bank sits at the measurement floor of about 10 searches a month. BIN sponsorship queries run marginally higher in the UK and are still small. That is thin demand rather than a hidden market, and we would rather say so than imply a non-US sponsor-bank category nobody is searching for.
For a business operating across borders, the practical consequence is that who is my sponsor bank is the wrong question outside the US. The right one is which authorised institution holds the funds, under which regulator, and what the settlement path looks like. Our country acceptance data covers that market by market.
What Boldrails provides
What Boldrails provides
Boldrails is a licensed principal provider. We hold the necessary licences required in the markets we serve, and we acquire, settle and disburse directly. We are most useful to businesses that other providers decline: crypto, forex, iGaming, and high-volume cross-border merchants.
Two things separate what we offer. The first is acceptance. We underwrite verticals that no bank in this register publishes a policy on, and you get a yes or a no during onboarding instead of after months of diligence. Onboarding takes 3 to 14 days, depending on your case.
The second is settlement speed. On our own banking rails we settle in minutes, not T+2.
Every capability we publish carries an honest status label: Live, In onboarding, or On request. The current per-market position is in our country acceptance data, and the banking and settlement services page covers the account side, including accounts for crypto businesses, and how the whole capability is packaged is set out on our banking as a service page.
and we will tell you what we can do, in plain terms, before you sign anything.
Tell us your vertical, volumes and corridors
We will tell you what we can do, in plain terms, before you sign anything, and we will price BIN or deposit sponsorship for your case.
FAQ
Frequently asked questions
Last updated: 2 August 2026. Written by Claude Igrow.