{"asOf":"2026-09-05","merchant":"SSDF INC","disclaimer":"SSDF maps Banking-as-a-Service clerks, FBO structure, the Synapse failure, and Florida ch. 560. SSDF is not a bank, not BaaS middleware, not an MSB, not a card issuer, and not a KYA provider.","live":{"human":"/baas","index":"/api/baas","card":"/api/baas/{slug}"},"objects":[{"object":"Charter / deposits","holder":"Sponsor bank (OCC, Fed, or state)","sells":"Nothing. The bank holds the FBO."},{"object":"Middleware ledger","holder":"BaaS platform (Synapse was this)","sells":"A map of who failed and who was ordered. Not a replacement ledger."},{"object":"First-party SKU","holder":"SSDF INC, merchant of record","sells":"This atlas, and a Passport over the purchase."}],"hardRules":["SSDF is a Florida C-Corp merchant of record. SSDF is not a bank, not BaaS middleware, and not a money services business.","The sponsor bank is the clerk for insured deposits and BSA. Middleware is not the clerk.","An FBO omnibus account is the bank's ledger. A middleware sub-ledger is not FDIC insurance and is not a substitute for daily reconciliation.","Fla. Stat. ch. 560 has no clean agent-of-the-payee walkaway. Florida looks at whether money was received and then sent onward.","Accepting USDC for first-party SKUs is SSDF retail settlement. Issuing accounts, cards, or agent wallets is someone else's charter.","A Passport attests that a buyer paid a SKU. It is not CIP, not KYA, not a QEAA, and not 'this agent is the bank's customer.'","Map the actors. Do not endorse a BaaS provider. Do not sell a bank."],"roles":[{"id":"sponsor_bank","title":"Sponsor bank","kicker":"The clerk for deposits","body":"Chartered depository. Holds the for-benefit-of (FBO) omnibus account. BSA/AML, fair lending, and reconcilation stay with the bank even when a fintech faces the customer. Outsourcing the activity does not outsource the charter."},{"id":"middleware","title":"BaaS middleware","kicker":"Ledger in the middle","body":"Connects fintech brands to sponsor banks. Typically no bank charter and no FDIC insurance of its own. The Synapse failure was a recordkeeping failure: no single party had a complete, accurate map of which end user owned which dollars at which bank."},{"id":"program_manager","title":"Program manager / fintech brand","kicker":"The face, not the charter","body":"Customer-facing app. Sells the checking account, card, or wallet UX. Relies on the sponsor bank for the regulated activity and often on middleware for the sub-ledger."},{"id":"end_user","title":"End user","kicker":"The person who could not get the money","body":"Consumer or small business whose balance sat in an FBO. After Synapse, many could not withdraw for months while bank ledgers and middleware ledgers disagreed."},{"id":"regulator","title":"Regulator","kicker":"The actual clerk","body":"OCC, FDIC, Federal Reserve, CFPB, and state OFRs. Consent orders after 2022–2025 ran against the chartered banks, not only the middleware. Florida OFR licenses money transmitters under ch. 560."},{"id":"merchant","title":"First-party merchant","kicker":"SSDF's actual seat","body":"Sells its own digital goods. Prices in USD. Settles in USDC on Base through Coinbase Business. Does not hold third-party balances, does not issue accounts or cards, and does not transmit value between other people's customers."}],"clerks":[{"id":"occ","title":"OCC","kicker":"National banks"},{"id":"fdic","title":"FDIC","kicker":"Deposit insurance + state nonmembers"},{"id":"fed","title":"Federal Reserve","kicker":"State member banks"},{"id":"cfpb","title":"CFPB","kicker":"Consumer harm"},{"id":"fl_ofr","title":"Florida OFR","kicker":"Ch. 560 clerk"}],"events":[{"id":"lineage-fdic","date":"2024-01","title":"FDIC consent order — Lineage Bank","kicker":"Sponsor bank"},{"id":"synapse-petition","date":"2024-04-22","title":"Synapse Chapter 11","kicker":"Middleware failure"},{"id":"evolve-fed","date":"2024-06","title":"Federal Reserve C&D — Evolve Bank & Trust","kicker":"Sponsor bank"},{"id":"fdic-fbo-proposal","date":"2024-10","title":"FDIC custodial-account recordkeeping proposal","kicker":"Watch the NPR"},{"id":"cfpb-synapse","date":"2025-09","title":"CFPB stipulated judgment — Synapse","kicker":"Consumer fund"},{"id":"house-baas-2026","date":"2026-05-20","title":"House Financial Services — Synapse record","kicker":"Congressional clerk"}],"actors":[{"id":"synapse","name":"Synapse Financial Technologies","status":"failed","kicker":"The middle ledger"},{"id":"evolve","name":"Evolve Bank & Trust","status":"enforcement","kicker":"Primary Synapse partner bank"},{"id":"lineage","name":"Lineage Bank","status":"enforcement","kicker":"FDIC order, then Synapse fallout"},{"id":"blue-ridge","name":"Blue Ridge Bank","status":"enforcement","kicker":"OCC BSA/AML"},{"id":"anchorage","name":"Anchorage Digital Bank","status":"agentic_bank","kicker":"OCC-chartered digital asset bank"},{"id":"interlace","name":"Interlace Agent Card","status":"msb","kicker":"Card for agents"},{"id":"unit","name":"Unit","status":"mapped","kicker":"Embedded-finance platform"},{"id":"treasury-prime","name":"Treasury Prime","status":"mapped","kicker":"US bank-partner coordination"},{"id":"solaris","name":"Solaris","status":"mapped","kicker":"EU BaaS bank"},{"id":"stripe-treasury","name":"Stripe Treasury","status":"mapped","kicker":"Embedded treasury for Stripe users"}],"florida":{"statute":"Fla. Stat. ch. 560 (Money Services Businesses)","residual":"The national BaaS pitch (API + sponsor bank + FBO + program manager) is written for a 50-state product. Florida is the residual risk point because the statute does not give the same exemptions. This atlas exists so an agent does not paste a national pitch over ch. 560."},"nationalPitch":{"title":"The national BaaS pitch","body":"License the bank. Embed accounts, cards, and payouts via API. Hold end-user balances in an FBO. Let middleware sub-ledger the beneficial owners. Sell the brand, not the charter.","breaks":"Synapse showed the sub-ledger can diverge from the bank. Post-2024 orders showed the charter still eats the exam. Florida showed the exemptions you were counting on may not exist."},"agentic":{"title":"Agent accounts vs merchant 402","body":"Anchorage sells regulated accounts for agents. Interlace sells a card the agent cannot take to an ATM. x402 exact is a typed USDC authorization to a merchant payTo. Coinbase Spend Permissions and card-network rules do not bind an exact PAYMENT-SIGNATURE. SSDF is the merchant on that last rail."},"sku":"ssdf-baas-atlas","doctrine":{"surface":"The sponsor bank is the clerk for insured deposits and BSA. Middleware is a sub-ledger. Synapse showed the two can diverge. SSDF publishes a machine-readable atlas of that surface, the public docket, and Florida ch. 560 against a national BaaS pitch.","filter":"Map the actors. Credential the purchase. Do not become the bank, the middleware, or the MSB. That is the title-file rule on a different clerk.","florida":"Fla. Stat. ch. 560 has no clean agent-of-the-payee walkaway. Desk Credits stay closed-loop. First-party USDC through Coinbase Business is retail settlement, not a third-party send.","identity":"A Passport attests that a buyer paid a SKU. It is not CIP, not KYA, and not 'this agent is the customer.' Sit this atlas next to Agent Identity Protocol."}}