From January 2020 to the present, Madison Avenue distributed or made available to customers consolidated reports containing inaccurate information, or omitting material information, about whether certain assets were held away from the firm, in violation of FINRA Rules 2210(d)(1) and 2010. The firm additionally failed to maintain records of which consolidated reports were distributed or made available to customers, in violation of FINRA Rule 4511, Section 17(a) of the Securities Exchange Act of 1934, Exchange Act Rule 17a–4(b)(4), and FINRA Rule 2010.

The Department of Enforcement alleges: 1. This case involves “banking-as-a-service,” a business model that allows financial technology companies (“fintechs”) to provide online banking services to members of the public (“end users”). 2. The fintechs, which are not banks, partner with licensed banks, which in turn hold end user funds. 3. Non-FINRA member Synapse Financial Technologies, Inc.