Bank's Bitcoin Finder Service Review

FDIC
DIVISION OF RISK MANAGEMENT SUPERVISION
FEDERAL DEPOSIT INSURANCE CORPORATION

Dallas Regional Office
600 North Pearl Street, Suite 700
Dallas, Texas 75201
(214) 754-0098 FAX (972) 761-2082


May 18, 2022

Memo To: File
XXXXX

From:
b8
Case Manager

Subject: Second Call Regarding Bitcoin Finder Service

On April 14, 2022, the writer telephoned President/CEO XXXXX of the above bank to enquire about the status of the bank’s plan to launch a Bitcoin finder service for customers. The following information was obtained.

  • The service went live on XXXXX.
  • There have been 80 transactions totaling $92,000. Seventy transactions were purchases and ten were sales. The sales totaled $1,800, so most transactions have been buy and hold situations. One person is responsible for approximately $50M of the purchases. Some of the transactions were bank employees who were testing the product if they wanted to. However, those were seemingly live transactions. A spreadsheet of transactions is attached.
  • Based on the transaction list, approximately 36 people who have executed transactions, but some of those are bank employees.
  • No complaints received from anyone.
  • No technology issues have arisen.
  • No unusual customer activity observed.
  • No other banks in XXXXX group are involved as far as President XXXXX knows.

XXXXX was informed that the FDIC may ask the bank to suspend the service, while the various issues are being considered at a national level. XXXXX noted that customers can open XXXXX accounts and transfer funds from the banking system without restriction, so it is unclear why this service is problematic.


TransactionId XXXXX UserId ... OrderId confirmedTime
1016 BUY 73.5 ... 1.5 TRANSFERRED XXXXX
1024 BUY 9.8 ... 0.2 TRANSFERRED XXXXX
1023 SELL 0.98 ... 0.02 TRANSFERRED XXXXX
1022 SELL 1.43 ... 0.03 TRANSFERRED XXXXX
1021 BUY 2.94 ... 0.06 TRANSFERRED XXXXX
1008 BUY 19.6 ... 0.4 TRANSFERRED XXXXX
1070 BUY 98 ... 2 TRANSFERRED XXXXX
1068 SELL 102.5 ... 2.09 TRANSFERRED XXXXX
1032 BUY 98 ... 2 TRANSFERRED XXXXX
1011 BUY 88.2 ... 1.8 TRANSFERRED XXXXX
1004 BUY 9.8 ... 0.2 TRANSFERRED XXXXX
1043 BUY 19.6 ... 0.4 TRANSFERRED XXXXX
1067 SELL 102.3 ... 2.09 TRANSFERRED XXXXX
1029 BUY 98 ... 2 TRANSFERRED XXXXX
1019 BUY 19.6 ... 0.4 TRANSFERRED XXXXX
1006 BUY 98 ... 2 TRANSFERRED XXXXX
1005 BUY 9.8 ... 0.2 TRANSFERRED XXXXX
1025 BUY 49 ... 1 TRANSFERRED XXXXX
1072 SELL 49.99 ... 1.02 TRANSFERRED XXXXX
1030 BUY 49 ... 1 TRANSFERRED XXXXX
1055 BUY 29.4 ... 0.6 TRANSFERRED XXXXX
1044 BUY 19.6 ... 0.4 TRANSFERRED XXXXX
1009 BUY 9.8 ... 0.2 TRANSFERRED XXXXX
1066 BUY 4900 ... 100 TRANSFERRED XXXXX
1049 BUY 4900 ... 100 TRANSFERRED XXXXX
1078 BUY 490 ... 10 TRANSFERRED XXXXX
1059 BUY 490 ... 10 TRANSFERRED XXXXX
1055 BUY 980 ... 20 TRANSFERRED XXXXX
1046 BUY 980 ... 20 TRANSFERRED XXXXX
1036 BUY 9800 ... 200 TRANSFERRED XXXXX
1071 BUY 98 ... 2 TRANSFERRED XXXXX
1060 BUY 98 ... 2 TRANSFERRED XXXXX
1058 BUY 98 ... 2 TRANSFERRED XXXXX
1042 BUY 98 ... 2 TRANSFERRED XXXXX
1007 BUY 98 ... 2 TRANSFERRED XXXXX
1010 BUY 19.6 ... 0.4 TRANSFERRED XXXXX
1045 BUY 490 ... 10 TRANSFERRED XXXXX
1075 BUY 490 ... 10 TRANSFERRED XXXXX
1073 BUY 490 ... 10 TRANSFERRED XXXXX
1062 SELL 1012 ... 20.65 TRANSFERRED XXXXX
1053 BUY 392 ... 8 TRANSFERRED XXXXX
1051 BUY 490 ... 10 TRANSFERRED XXXXX
1041 BUY 98 ... 2 TRANSFERRED XXXXX
1027 BUY 98 ... 2 TRANSFERRED XXXXX
1020 BUY 98 ... 2 TRANSFERRED XXXXX
1002 SELL 19.6 ... 0.4 TRANSFERRED XXXXX
1000 BUY 49 ... 1 TRANSFERRED XXXXX
1031 BUY 490 ... 10 TRANSFERRED XXXXX
1061 BUY 49 ... 1 TRANSFERRED XXXXX

1057 BUY 98 2 TRANSFERRED 1050 BUY 19.6 0.4 TRANSFERRED 1048 BUY 98 2 TRANSFERRED 1013 BUY 490 10 TRANSFERRED 1033 BUY 490 10 TRANSFERRED 1077 BUY 9800 200 TRANSFERRED 1076 BUY 19600 400 TRANSFERRED 1054 BUY 9800 200 TRANSFERRED 1052 BUY 9800 200 TRANSFERRED 1037 BUY 490 10 TRANSFERRED 1018 BUY 490 10 TRANSFERRED 1015 BUY 98 2 TRANSFERRED 1014 SELL 24.5 0.5 TRANSFERRED 1001 BUY 98 2 TRANSFERRED 1017 BUY 19.6 0.4 TRANSFERRED 1012 BUY 9.8 0.2 TRANSFERRED 1034 BUY 98 2 TRANSFERRED 1026 BUY 98 2 TRANSFERRED 1035 BUY 19.6 0.4 TRANSFERRED 1079 BUY 98 2 TRANSFERRED 1074 BUY 411.6 8.4 TRANSFERRED 1064 BUY 98 2 TRANSFERRED 1028 BUY 980 20 TRANSFERRED 1039 SELL 474.35 9.68 TRANSFERRED 1038 BUY 490 10 TRANSFERRED 1047 SELL 49 1 TRANSFERRED 1040 BUY 98 2 TRANSFERRED 1033 BUY 98 2 TRANSFERRED 1063 BUY 3920 80 TRANSFERRED 1056 BUY 980 20 TRANSFERRED 1059 BUY 4900 100 TRANSFERRED

XXXXX XXXXX XXXXX