The findings point toward a safer operating design: preserve the speed of embedded finance while making ownership, reconciliation and accountability visible at every layer.

WorkedDid not

Customer visibility

80% partnership reach

individual transparency gap

Reconciliation

three in four reported losses

up to $95m shortfall

Regulatory confidence

more than 25% FDIC actions

over 20% OCC actions

Program appetite

nearly 30% considering retreat

80% partnership strain

The comparison is not a claim that a particular control fixed Synapse. The findings describe the breakdown and its consequences, not a completed replacement system. They do show what a robust response would need to address: a clear customer-level ledger, timely reconciliation between the intermediary and sponsor bank, and evidence that balances can be explained before withdrawals depend on them.

Responsibility also needs to remain visible across the partnership. The enforcement pattern shows that sponsor banks were not outside the consequence chain. More than 25% of FDIC enforcement actions in 2024 and over 20% of OCC enforcement actions targeted sponsor banks involved in embedded finance.² A workable model therefore pairs innovation with oversight that can test records, escalation routes and customer access before a failure occurs.

Embedded finance provider Synapse collapsed, customers lost access to funds