If a user has money in their account and the app creator goes under, they lose access but the actual bank hasn’t failed. Insurance on the account doesn’t kick in because there’s no bank failure to mitigate, but the user still doesn’t have access to their money before.
These regulations weren’t written with banking-as-a-service in mind, and don’t hold up well now that it’s not a weird edge case but a primary way companies provide banking services.
Cashapp doesn’t hold customer money. It has banking partners that hold customer funds.
There’s a secondary problem.
If a user has money in their account and the app creator goes under, they lose access but the actual bank hasn’t failed. Insurance on the account doesn’t kick in because there’s no bank failure to mitigate, but the user still doesn’t have access to their money before.
These regulations weren’t written with banking-as-a-service in mind, and don’t hold up well now that it’s not a weird edge case but a primary way companies provide banking services.