{"asOf":"2026-09-05","merchant":"SSDF INC","kind":"role","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.","clerk":"OCC, Federal Reserve, FDIC, or state banking department — depending on the charter.","ssdf":"SSDF does not sponsor programs and does not hold FBO funds."}