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Raisin is a financial marketplace that allows you to access high-interest certificates of deposit and savings accounts from multiple different banks and credit unions without having to open up a new account at each one. Right now, they have some new deposit bonuses that are pretty solid based on the bonus-to-deposit ratios and minimum holding periods. However, I will personally not be taking advantage of them due to their use of custodial FBO accounts. I think it’s most useful to both point out the existence of these bonuses and explain my take on them. Details below.

Here are the new bonuses:

• New customer $250 bonus. Open a new account with promo code GET250, deposit $25,000 within 14 days, and maintain for 90 days for the $250 bonus.
• Existing customer deposit bonus, up to $400. Must deposit $50,000 in new money. $200 on a 3–6 month CD. $300 on a 7–11 month CD. $400 for a 12+ month CD. Must maintain for full CD maturity period.

How Raisin works. The benefit of Raisin is that you can easily access aggressively high rates at a new bank or credit union without having to open yet another new account (and endure credit checks, identify verification hurdles, join partner organizations, leave funds in share savings accounts, etc). The price is added complexity, higher risk for miscommunication and errors, and a place in a regulatory shadow zone.

Instead of opening a direct account at a new partner bank, there are at least three different parties.

• Raisin, which is the overall business (“financial technology company”) and not a bank and not a credit union. (Source #1)
• There are the middlemen, Custodial Bank(s) and Service Bank. The Custodial Bank opens up FBO (For Benefit Of) accounts at each of the Partner Banks/Credit Unions in THEIR names. These FBO accounts are basically big pooled accounts, and the Custodial Bank is supposed to keep track of all the money going in and out for all the individual Raisin customers in their own virtual ledger. The Service Bank is in charge of moving your funds amongst the various banks. Central Bank of Kansas City (CBKC), Member FDIC, is the Service Bank. CBKC, Lewis & Clark Bank and Starion Bank, each Member FDIC, are the Custodial Banks. (Source #2)
• There are the partner banks. These banks and credit unions are looking to grow deposits, but they have no idea who you are as an individual. They come and go on the Raisin platform. They only see that they opened a single, huge FBO account for the Custodial Bank. (Source #3)

While this setup appears to be perfectly legal (as far I can tell, I am not a lawyer), that doesn’t mean that there is someone to clean up the mess if something goes wrong. It’s like if someone steals your wallet and the cops are too busy with violent crime to track them down, it doesn’t matter if it’s illegal, you’re still not getting your money back.

The real-world example is what happened with Juno, Yotta, Synapse, and Evolve Bank & Trust. They had major disagreements about the ledger tracking all the deposits and withdrawals. They all blamed each other for the missing funds (~$50 million). Since no bank actually failed, the FDIC did not step in. No other regulatory agency stepped in. I was surprised. It was all left to a severely-underfunded bankruptcy court, and the mess still isn’t figured out. Someone ran off with tens of millions of dollars, and innocent individuals were left holding the bag.

Source #1:

Raisin is not a bank and your money is always handled by a federally regulated financial institution — whether in transit, stored in the Cash Account, or in an account at a partner bank. The Custodial Bank keeps records of all funds deposited through the Raisin platform for added security.

Source #2

Custodial accounts are accounts held on for the benefit of Raisin customers by a custodial bank at the banks and credit unions where customers deposit their money through Raisin. When a customer makes a deposit through the Raisin platform into a savings product offered by a given financial institution, the funds move from the customer’s external bank account (also referred to as their reference account) to a custodial account held by one of Raisin’s partner custodial banks at the financial institution offering the savings product. Central Bank of Kansas City (CBKC), Lewis & Clark Bank and Starion Bank, each Member FDIC, are the Custodial Banks.

Source #3:

An FDIC-supervised custodial bank opens the “For Benefit Of” account for each customer and agrees directly with Raisin’s customers to act as the custodian of their funds. This custodial bank is authorized by Raisin customers, as their agent, to hold their deposits at federally regulated banks and credit unions on their behalf in a custodial capacity. Customer funds are never co-mingled with Raisin funds.

Again, if everyone does what they say they will, then it’s all good. The problem is what happens when they don’t. If it happens with Raisin (or any of the parties involved, all relatively small institutions), it has the potential to be a complete mess that could take years to untangle. In today’s regulatory environment, I have zero interest in putting my cash into any sort of regulatory grey area.

In contrast, the CIT Bank $225/$300 deposit offer involves a simple, direct relationship with CIT Bank, an FDIC-insured bank, where you have an individual/joint account directly held in your name. There is a single system. There is no potential pointing of figures between multiple parties. There is a long, established history of the FDIC stepping in resolve a bank failure within days. It’s about as safe as it gets.

Bottom line. I’m doing the CIT bank offer, but not the Raisin offer.

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