The $70 Billion Escheatment Problem for Banks, Fintechs and Crypto With Allen Osgood, CEO of Eisen

Escheatment is a $70 billion problem hiding in plain sight: every state, territory, and dozens of countries have laws that hand dormant and unclaimed accounts over to the government after three to five years of inactivity. Allen Osgood, co-founder and CEO of Eisen, left a five-and-a-half-year run as a payments product manager at Coinbase to build the compliance infrastructure that helps banks, brokerages, and crypto platforms reunite customers with their money before the states ever claim it. In this conversation Allen makes the case that crypto is about to collide with escheatment rules written in the 1960s, and that most institutions have no idea how large their own dormant balances really are.

What We Covered

• What escheatment actually is and how the state-by-state rules work
• The $70 billion states are holding for more than one in seven Americans
• missingmoney.com and what happens after money is remitted
• Ohio’s fight over using unclaimed property to fund a football stadium
• The Walter story: an E-Trade Amazon account liquidated to Delaware
• What counts as a “dormant” account and why logins matter
• Where Eisen plugs into the escheatment process
• Why reactivation beats remittance, and the Binance.US 48% case study
• Why institutions are blind to their largest dormant balances
• The 12-to-24-month gap where accounts just age untouched
• Displacing big-four spreadsheets with a single pane of glass, forecasting, and access controls
• Data volume as the hardest engineering problem, and where AI earns its keep
• The Claims Portal and QR-code reactivation
• Why crypto makes escheatment far more painful, from volatility to dust
• The coming wave of crypto liquidations and the tax problem
• Channel strategy with the cores like Fiserv, and the road to 1099 and tax reporting

Key Takeaways

• The best escheatment outcome is no escheatment at all. Eisen’s real value is retention: keeping customers, deposits, and assets in the institution rather than shipping them to the state.
• Institutions routinely underestimate their exposure. One prospect thought it had 10,000 accounts about to escheat, the real number was 100,000. The disconnect sits between the compliance team and the data on the ground.
• Crypto changes the stakes. States generally require liquidation, so a dormant token gets sold, creating an unwanted taxable event and, if the market rips afterward, another Walter waiting to happen.
• Stale data is the enemy. The information that comes due for escheatment is by definition three to five years old, so address enrichment (LexisNexis, Socure, USPS NCOA) and early engagement are what actually move the reactivation numbers.

About Allen Osgood

Allen Osgood is the co-founder and CEO of Eisen, a compliance operations platform that automates escheatment and account offboarding for financial institutions. Before founding Eisen, he spent about five and a half years as a payments product manager at Coinbase, where he first ran into the strange world of unclaimed property and stayed through the company’s IPO.

Cleaned Transcript

Allen (00:10): What escheatment laws require you to do is at least annually look at every single account that comes through your system, check it, based on the address on file, against the appropriate set of state laws that determine dormancy. If it’s dormant, according to that state’s specific treatment of abandoned property, usually you’re required to send a letter, physical mail, by law. So it could be first class, certified, whatever. Then if you hear back, great, you don’t have to escheat it. That resets the dormancy period. But if you don’t hear back, you have to file a report and remit that account to the state. You effectively lose the customer. And so where Eisen plugs in is we take in those accounts from our customers, run them through a complex rules engine that we’ve built with the help of a bunch of external counsel, and help them identify which accounts are going to escheat versus not, and get ahead of that entire process.

Peter (00:56): This is the Fintech One-on-One Podcast, the show for fintech enthusiasts looking to better understand the leaders shaping fintech and banking today. My name is Peter Renton, and since 2013 I’ve been conducting in-depth interviews with fintech founders and banking executives. My guest today is Allen Osgood, the CEO and co-founder of Eisen. Before starting Eisen, Allen was a payments product manager at Coinbase, where he stayed through the company’s IPO and first ran into the strange world of unclaimed property. In our conversation, we go deep on escheatment, the $70 billion problem where abandoned bank, brokerage, and crypto accounts get handed over to the states. Allen explains why so many banks and fintechs dramatically underestimate their own dormant balances, how Eisen re-engages customers before their money is lost, and why crypto makes the whole problem far more painful. We also talk about the role AI plays in normalizing massive data sets, his channel strategy with core providers like Fiserv, and where the business is today after their recent Series A. Now, let’s get on with the show.

Peter (02:12): Welcome to the podcast, Allen.

Allen (02:14): Peter, great to see ya.

Peter (02:15): Great to see you. So let’s kick it off by giving the listeners a little bit of background about yourself. Take us through some of the high points of your career to date.

Allen (02:26): Sure. So I’m the CEO of Eisen. I’ve been CEO for the last four or five years now. Prior to this, I was the payments product manager at Coinbase from 2018 through about the IPO. Fell in love with low-level, important compliance infrastructure and set out to build what I thought would be the next most important thing to solve there.

Peter (02:45): So before we get really into it, I need you to describe what escheatment is, and I hope I’m saying that right. But I’d never heard of this term until a few years ago, and it’s not obvious what it means from the word itself. So for those people who are listening that have never heard of this term or don’t understand what it is, please explain.

Allen (03:04): Sure. So escheatment’s a $70 billion problem where every different state in the US, all the different territories, and 40-plus countries around the world have laws that govern what happens to abandoned accounts. So the checking account that you opened in college, the retirement account that your father had when he passed away, there’s billions and billions of dollars within our financial system that goes unclaimed every year. And after three years in most states, five years in some, those assets are closed out and sent to the state as required by law. So the states are holding more than $70 billion for more than one in seven Americans. There’s actually a website you can go to just to search and see if you’re owed some money. That’s called missingmoney.com. It’s a bunch of the states that got together to basically build a shared database of assets that have been turned over to them through the kind of state-by-state compliance that every bank, brokerage, credit union, crypto firm, and a variety of others actually have to go through, following the compliance rules to send that money to the state every year.

Peter (04:02): So when the state gets the money, do they just have to hold it in trust? I mean, they’re not using it for their state budget, right?

Allen (04:07): Depends on the state. States will hold it in perpetuity to be returned to the claimant. The states typically keep the interest on those funds. And then some states try to use those funds for government purposes. So the state of Ohio recently had a bit of a kerfuffle when they tried to use unclaimed property funds to help fund a football stadium. And so, I wish I could make some of these stories up, but it’s something that affects millions and millions of people that most people don’t actually know. That clock is running when they open that crypto wallet, when they open that new fintech bank account, when they have that gift card. And so really, where we try to help is to help the companies comply with the rules, to try to reunite people with their money before escheatment ever kicks in in the first place.

Peter (04:48): It was interesting. You spent some time at Coinbase, as you said, and going from Coinbase to escheatment is not exactly a typical thing to do. Most people leave Coinbase and start the next exchange or crypto wallet or some sort of crypto infrastructure. What did you see from inside Coinbase that convinced you that escheatment was the problem worth building a company around?

Allen (05:16): So I think when you’re in the belly of financial services, you see a whole host of problems, some of which I think are more consumer-affecting than others. Toward the end of my time there, I saw us having to liquidate a hundred-plus million dollars. And that always just kind of struck me as very strange. Why in the world would we be going through and closing customer accounts when we spent so much time trying to onboard them and activate them? And that was my first introduction to the crazy world of unclaimed property. And so, fast forward, I heard a podcast. Have you ever listened to NPR’s Planet Money?

Peter (05:50): I do, yes.

Allen (06:15): So they did a big feature on a guy named Walter. And what Walter had done is he bought Amazon shares in the ’90s and put them into an E-Trade account. That turned out to be an incredible time to buy Amazon stock, it went on one of the most historic runs ever. But he was doing what we’re all taught to do growing up, which is, if you think you have a good investment, set it, forget it, let it go up. That just turns out to be a terrible idea, because Walter had moved. So the escheatment rules that E-Trade was following were to look at his account, see that it’s inactive. They tried to send him a letter, which is the minimum requirement. They didn’t get a response. So they liquidated him and sent his money to the state of Delaware. So he got liquidated in 2008. When he went to retire in 2018, what he thought was his retirement savings from a winning investment was a fat zero. And so he then proceeded to sue everybody. He sued E-Trade, Morgan Stanley, he sued the state of Delaware. And he lost all the cases, because they’d followed the escheatment rules. But in what scenario is that actually a win? Walter hadn’t forgotten about his money. He simply hadn’t connected with the institution. And when they’d followed the bare-minimum legal requirements of sending a letter, he hadn’t gotten it. And so what was designed originally as a consumer protection regime, to try to take lost funds and give them back to people, has in today’s digital asset age and today’s securities age actually created a whole host of consumer harm.

Peter (07:11): Dormant account, does that mean you haven’t logged in? I have accounts that I don’t trade on. They’re long-term investments. How does it define a dormant account?

Allen (07:20): So usually activity will be any written form of contact between you and the institution. So that might be you’ve logged in and they’ve recorded it in their database. That might be you’ve done a transaction using a debit card, that would basically be engagement that would cause it to reset. But you have to do something with that company for them to know you’re still there. And this whole thing, if you rewind it all the way back, escheatment comes from an old English term, when the crown would bestow property on people, and if they abandoned it, it would revert back to the crown. Now you apply that to 54 different states and jurisdictional territories, and you’re going to have a totally different set of complexity to manage, which in today’s digital financial age is where a lot of the pain pops up.

Peter (08:01): Can you just take us through Eisen’s offering? What exactly do you do, and how does it work?

Allen (08:08): Totally. So let’s start with the escheatment process, and I’ll talk about where we plug into that. Let’s take a fintech company as an example here. So say you offer your fintech products and services to customers nationwide. You work with a sponsor bank relationship. You have customers in all 50 states. So every customer signs up, they fund their account, they use it. Each of those accounts has an associated last activity date. And so that account’s going to have the last transaction, the last login that that customer had. What escheatment laws require you to do is, at least annually, look at every single account that comes through your system, check it, based on the address on file, against the appropriate set of state laws that determine dormancy. If it’s dormant, according to that state’s specific treatment of abandoned property, usually you’re required to send a letter, physical mail, by law. So it could be first class, certified, whatever. Then if you hear back, great, you don’t have to escheat it. That resets the dormancy period. But if you don’t hear back, you have to file a report and remit that account to the state. So you effectively lose the customer. And so where Eisen plugs in is we take in those accounts from our customers, run them through a complex rules engine that we’ve built with the help of a bunch of external counsel, and help them identify which accounts are going to escheat versus not, and get ahead of that entire process. So we help manage the compliance operations, but more importantly, and what we get more excited about, is we help drive retention of those accounts in the first place. And so the best outcome for escheatment is no escheating at all. So if we can drive that as close to zero as possible, we’re going to end up in a better place for that customer, we’re going to keep that money in that fintech and that bank, and we’re going to keep that money out of the state’s coffers. That’s ultimately, I think, the real goal of where our business sits. And so we automate that process for our large clients.

Peter (09:51): This is obviously things they’re not doing now. Is it just a simple case of contacting them in better ways? I mean, what is it that is different about what you guys do versus what the bank or fintech is already doing?

Allen (10:05): So I think there’s a couple of more proactive things you can do. Email outreach is a great first example. A lot of places, when you get to that two-to-three years of dormancy, they aren’t doing re-engagement efforts with that customer. But more importantly, it’s looking up new contact information. So can we run that account through LexisNexis, through Socure, through one of the address enrichment platforms, to be able to find the new mailing address? Or are we using things like USPS NCOA, the National Change of Address database, when we send that letter? So it’s doing these thoughtful things at every step to try to find that customer where they are, not just where they told you they were three to five years ago when they might have opened that account with you. And so the data that comes due for escheatment is, by definition, stale. And using stale data to try to reactivate and re-establish connection with somebody is a losing proposition. And so that’s where, as we get more time ahead of this, we can be more proactive, we’ll check against all of these external sources to try to find where that person’s actually gone.

Peter (11:05): That makes sense. So why are financial institutions so blind to their own large dormant balances?

Allen (11:14): The largest account that we came this close to escheating was about $9 million. And so we’re talking wildly material balances. These are not cents in a gift card account, these are life savings. So the best I’ve come up with on this is that I think a lot of it is a case of the right hand not knowing what the left hand’s doing. When an account goes dormant after about 12 to 15 months, that gets labeled as dormant in the bank core, that gets pulled off of the reactivation campaigns. Usually it kind of gets set as a lifetime value of zero from then on, until about month 24, when the compliance team picks it up to start the escheatment processing. So from about 12 months to 24 months of dormancy, almost nothing happens to those accounts. They just sit there. They just age. We’re not inventing rocket science here, Peter. We’re just being proactive about re-engaging accounts throughout their life cycle. You’ve spent all of this effort to sign somebody up, you’ve spent all of this effort to activate them, they’ve become activated, it’s just the life cycle of how these things play out. But I think a lot of it is that handoff between “this is an engaged, active, business-owned and managed account” and “this is picked up by the compliance team according to escheatment timelines.” That gap is immense. And there’s a ton of opportunity to actually reactivate what is potentially just a forgetful client.

Peter (12:37): So then, is that 12-to-24-month period the time period where you become engaged with the bank or fintech?

Allen (12:45): That’s typically where we can see the biggest return. And so, yes, doing something at 24, 36 months of inactivity, we can help save some of those clients. But the earlier you go in that account’s life cycle, the more successful you’re going to become, because the less stale the information is. It’s much more likely that you have the right address, but they simply haven’t logged in, than that they might have moved or had a whole host of other things play out. But when we throw the kitchen sink at it, we just published a case study with Binance.US where we hit 48% reactivation through their fall processing. We threw the kitchen sink at going to retain those assets, and we were wildly successful in doing so.

Peter (13:22): One of the things you also said was that what companies have typically done is they have Excel spreadsheets, they engage with some of the big-four accounting firms that have some software. So when you walk into a company that already has, like, Deloitte or PwC or what have you, and they have a process, shall we say, what are you showing them that wins the deal for Eisen?

Allen (13:46): So there are typically three reasons that people switch over to us. The first is to have a single pane of glass that everybody in your organization is able to take a look at. Having a dashboard, having a product, having a list of accounts that is constantly getting updated, escheatment touches many, many different internal teams. It’s going to touch legal, it’s going to touch compliance, it’s going to touch operations. Everybody needs to be involved and engaged with what’s going on. And so having one place that everybody can log into that’s constantly getting refreshed with data is a huge advantage for the companies that we work with. The second is forecasting. So being able to tell not just what’s about to happen right now for the state deadline right ahead of us, but to understand what’s coming next year, the next cycle, so that we can get ahead of things and have forecasts and understanding of what the liability is that’s about to go out the door. How much liquidity are we about to send to these states, so that you can prioritize your efforts as to where you want to go activate and engage? And the third is the ability to share limited versions of access and rules-based access controls with others. So we have a number of bank branch clients where the central group will manage the full list of accounts. We’ll have which branch those things belong to, and we’ll create limited-view portals for those branch managers, or maybe that fintech compliance officer, if I’m a sponsor bank, to be able to see just their accounts. So you can coordinate across parties much more efficiently. And so you entrench and embed a single pane of glass that everybody’s able to share, to then make the rest of the process much smoother.

Peter (15:17): So then, what part in your process would you say is the hardest engineering problem? And we haven’t talked about AI yet, maybe in that, how are you implementing AI in your solutions?

Allen (15:28): Absolutely. So the hardest part of everything we do is the data volumes. We’re processing 15, 16 million accounts a week for different clients. And so being able to go through and manage the updates to that, the constantly refreshing of what are the balances, the login dates, how we remove people from the escheatment list up to the moment that we’re able to, AI has been a godsend for being able to normalize data sets to load them in for us. So how can we take a look at the structure of that data? How can we accelerate your go-live? How can we make sure that’s reliable and consistent? That’s been an incredibly effective tool for us to be able to increase the volume and scale of clients that we’re able to help.

Peter (16:08): In your press materials, you say that you’ve prevented more than 31% of at-risk assets from being lost to state custody in 2025. So how do you measure that number, and how can you increase it?

Allen (16:24): So when we take our measurements, we have the list that we start with. When we get ready to begin processing for a cycle, we take a look at all of the dormant accounts. That’s who we would start sending those letters to. That’s who we start to track. As you are right at the cusp of getting sent to the state, we begin outreach, we begin digital follow-ups, we begin potentially SMS communications, the ability to go throw the kitchen sink at trying to find folks. And then, as they log in, as they do transactions, as they respond to the letters we’ve sent them, we just launched a new product called Claims Portal, where we can send a QR code on the letters and emails that people can one-click to say, “please retain my account.” All we need is a documented version of communication between that customer and the financial institution to indicate an interest in that property, to then reset that dormancy clock. And so by simply giving somebody a link to scan, a QR code to scan to say, “hey, that’s my money, please don’t escheat it,” we’re going to keep that account open for another three to five years. And if you think about the benefits of the customer relationship staying open, the net income margin that you’re able to maintain on that deposit account, there are so many different follow-on benefits to that process of simply going the extra mile. And so we see pretty directly, when we go through and get address-enriched data from external data sources and use that as part of our retention process, we see that number spike even higher above 31.

Peter (17:46): So do your clients typically start off with a pilot and an A/B test, or do they go all in? I mean, how does someone implement Eisen?

Allen (17:55): So we have two models. The first is an anonymous POC. So customers can pull off any of the names and things like that, and we simply show you what your escheatment risk is. We give you a sample of exactly what’s going to happen to those accounts. But the vast majority of our clients simply want a solution that works. We don’t do a POC, we give them a demo, we show their whole team how it works. And then they want us to show, with their data, what’s actually going to happen. And so we have a view that we call the escheatment scorecard, state by state by state, what’s past due, what’s currently due, and what amount is total about to get sent to each of these different states on what timeline. That helps you understand very quickly, hey, even if you’re potentially behind the eight ball, what does that actual liability scale look like for you? And so some of the clients that we’ve worked with, they came in during pricing and negotiations and said, “hey, we have 10,000 accounts that we think are going to escheat.” Okay, great. We can work with that. And then we run the numbers, and it’s actually 100,000 accounts that are going to escheat.

Peter (18:54): How are they so wrong?

Allen (18:56): I think there’s, through no fault of anybody’s own, a disconnect between the people who own the compliance requirements and the data on the ground. And so what we try to do is create as much synergy between what the data says we need to do and what compliance says we need to do, and keep those things in lockstep. So when I think about our product and the things that we’re evolving, how do we make sure that we can give compliance officers and operations teams a one-stop shop, where you send us the account data that you want us to look at? And whether it’s escheatment, whether it’s data enrichment, whether it’s, I mean, Peter, you’ve seen production banking data. You know how messy that can get, whether it’s remediation, we can go through and help you with all of those pieces, so that we can basically give you an account compliance platform that allows you to do all the things that you need.

Peter (19:45): Okay, so let’s talk specifically about crypto escheatment, because that is why, obviously, you had the idea, it sounds like. And crypto is volatile. There are some people that bought Bitcoin at $200 and it’s sitting at, like, 60,000, and some of them have probably just forgotten about it. Tell us a little bit about how much of a problem this is in crypto. And what are the unique things about crypto that are different? So tell us a little bit about what is the state of that market.

Allen (20:20): Crypto broadly splits into custodial and non-custodial. Non-custodial is you manage your own private keys, you have your own passwords and phrases and those things, and you manage it yourself. So if a centralized exchange doesn’t have access to your stuff, you’re not going to get escheated. So Satoshi Nakamoto is safe, but if he’d been on an exchange, he would have been liquidated ten years ago. Meanwhile, you have the centralized custodial exchanges, your Coinbase and others of that type. And so within custodial exchanges, they’re subject to state-by-state unclaimed property laws. And many, many states have turned on and changed their rules to explicitly include what they would call virtual currency, all of Bitcoin, Litecoin, Ethereum, all of the major, major digital assets. And they typically put them on very similar dormancy periods to the rest of the assets we’ve talked about. So a bank account might be three years, a crypto wallet might be three years. They vary pretty broadly across asset types, but broadly speaking, they follow the same rules. California, for example, passed a bill to make crypto escheatable this year for the first time. There are five or six states that are following suit. And so what we’re seeing is that, across states, crypto is becoming part of the reportable unclaimed assets, whereas historically it might not have been. And one of the biggest challenges with crypto is that the asset prices are very volatile. You might also get things like airdrops, you might get forks, you might have dust left in accounts. And so even if you send assets out, you might have a little bit left, prices go up, and now that crypto exchange has another thousand accounts that they need to go through and escheat for a penny. So the problem here is that unclaimed property laws don’t have a minimum. Anything of a penny or up is reportable property, following all the sets of compliance rules that we’ve talked about. And so, despite your best efforts, if you have staking that puts interest in, if you have bonding that you need to unbond, there are all of these very crypto-specific things that end up not necessarily being accounted for in the way that the state statutes are written here, but that have huge implications for how you actually operationally manage this. But I think the core principle to come back to, though, is that price fluctuation. So the states require the companies to liquidate these assets, by and large. There are some states that are getting better about taking assets in kind. But broadly speaking, you might have Bitcoin go way up, that account goes dormant, and the state that this belongs to requires that company to liquidate it. And then the crypto price goes down, well, that customer, if they ever find out, is going to be thrilled. But it might have gone the other way. That asset might have gone up. And I think what’s going to happen is we’re going to wake up two to three years from now, after all of these things have kicked in, and we’re going to have a lot more of that Walter story that we talked about earlier, the people who thought they made a great financial investment, put it into a safe spot that they trusted, only to have it sold out from underneath them before the market continued to rip. So right now we’re in a bear market, but if I’ve learned anything from crypto, it’s that these things are volatile and there will be a bull market that comes back at some point. I want to make sure that we can do our darndest to try to reunite people with their assets before we actually end up in that situation that caused Walter so much pain.

Peter (23:30): Yeah, because here’s the thing. I mean, you liquidate someone’s crypto holdings and that becomes a taxable event. And so, through no intention, they might have been intending to hold this for another decade, and yet the state has gone and created a taxable event. How is that handled?

Allen (23:51): I think it shouldn’t happen, but unfortunately, that’s not how this works. But interestingly enough, there was a recent Supreme Court case where they ruled that you cannot force a taxable event on somebody else. So there’s going to be a fight about this at some point. And I hope you end up not being able to force liquidation upon an unwitting consumer. But if you imagine some of the tax bills that this spits out, from somebody who bought crypto early on and just let it go up, I think it’s a really rude awakening for a lot of people. And it’s a problem that, I think, for better or for worse, a lot of fintechs, as they get started, say, “we’re going to deal with that later.” It’s just that now, for a lot of them at scale, today is later. And so that three-year window, that five-year window, we’re crashing into this as people got spun up with Venmo, as people got their Coinbase account opened. We’ve seen everything that got opened during COVID now running into dormancy periods. Every benefit, every bonus that we saw on the back of the bull market is now coming due through a set of completely unthought-through side effects. It’s now causing a massive wave of items to hit the dormancy periods. And so we’re seeing a lot of consumers going through this for the first time who might not even know escheatment’s a thing.

Peter (25:05): Right. So then, is there a demographic where this is more common? I imagine that the demographic of crypto is quite different from the demographic of just dormant bank accounts, but can you give us some color there?

Allen (25:18): So we see a wide range of ages, of types, of asset classes that fall into this category. We have seen crypto become especially active as more and more states are flipping on support to make crypto reportable. But usually we see bank accounts, we see savings accounts, CDs, cashier’s checks, gift cards. A lot of the fintech wallets tend to skew a little bit younger, a lot of the traditional CDs tend to skew a little bit older. But a lot of it is, a lot of people, when we start the conversation, think, “yeah, isn’t that the process that kicks in when somebody dies?” Yeah, it absolutely is. But it’s also something that, if you think about it, these laws were passed in the ’60s and ’70s. This was when people had, on average, one to two bank accounts at their local bank. That’s simply not how finance works anymore. You can open up a bank account in the snap of your finger, and as long as you have any money in it at all, that company’s going to have to go through and escheat it in the next three or five years.

Peter (26:15): So then, I was also reading that you’re working to embed your technology into some of the cores. I think I read that Fiserv has no built-in escheatment functionality at all. Are you looking at this as a two-pronged strategy, going direct, and then also embedding your technology?

Allen (26:34): 100%. One of the biggest things for us is, how do we bring this awareness and this analysis to as many accounts as possible? And so the bank cores, the large-scale sponsor banks that we work with, everywhere that we see those accounts existing, we want to be able to embed escheatment knowledge and analysis and the ability to take an extra compliance process off the list that you have to worry about. And the Fiserv relationship has been extremely successful. And so as we push forward with multiple of those across the major cores, a lot of the growth of our business is focused on not just the direct sales and direct relationships, but also building out those channels, and how we can connect with as many of those different customers that need support as possible.

Peter (27:15): And I imagine the middle of the market is more your kind of sweet spot, right? Because the very large banks, I imagine, have their own processes, many people working on this problem every day. The smaller banks just don’t have very much volume that would make it probably difficult to make the economics work. But maybe you could talk about where your sweet spot is, and how you’re able to move up market potentially.

Allen (27:39): Absolutely. So we typically see our sweet spot of customers between 50,000 accounts and multiple millions of accounts. And so that range typically lends itself, in banking, to somewhere between $500 million to a billion, all the way up to about our largest, $25 billion, on the banking side. Where we’ve also seen great traction is on the brokerage side. So just last week we signed our largest brokerage client, our first in the trillion club. And so even at the massive scale of brokerages with a trillion dollars in assets, you’ll have multiple people working on this. But it is so much work that even that is insufficient. And so being able to bring better tools and automation and AI to these things in a way that lets you triage and appropriately manage your risk, the biggest problems, Peter, at the biggest institutions, are that you have so many different data sources that contain information about the same person. It’s almost a CRM challenge. And so we have a late-stage bank prospect with 37 different data sources. And so when you think about the operational challenge of combining that to understand what is the last contact state with Peter, when he might show up in one of 37 places, that’s where you get real benefits, from a governance, risk, and compliance perspective, from having one pane of glass that everything feeds into. And so it’s been fascinating to see the layers to this onion, as you understand that you need to build a holistic picture of that customer. You need to understand all of their assets, and you need to understand this crazy set of unclaimed property laws that you can actually combine to ultimately do this process well.

Peter (29:14): So then, can you give us a sense of the scale you guys are at today?

Allen (29:18): So we just raised our Series A earlier this year, so very excited about that. We announced there that we were doing about 16 million accounts a week, with about $19 billion in assets monitored. What we’re trying to do is make sure that we can build out that reactivation engine before people actually go to the escheatment process, and then, certainly, the operational process of actually going through escheatment and building your auditable, defensible record there. So about 50 clients, the business has been doing great. We just announced Coinbase as a client two weeks ago. So very exciting to see that come full circle, all the way back, the company that inspired you to start the thing is now a client using your thing. That’s a personal win. But we see a variety of different large-scale crypto clients, brokerage clients, credit unions, and banks, all really who have the same set of problems, trying to manage it to protect their customers as well as they can.

Peter (30:10): Okay, so last question. What’s your vision for Eisen, and what would you say success looks like for you guys in three years?

Allen (30:19): So if I fast-forward three years, I think we are monitoring the majority of consumer fintech accounts. That level of consumer finance, I think, is really where we want to play. But escheatment is one of about 20, 25 different obligations you have to be checking an account for on a regular basis. And so as we think about how we expand, one of the next big products we’ll be announcing in the next couple of months is 1099 and tax reporting. How do I do all of the pay management on top of this? How do I check for all of the related items I have to do there, that data enrichment we talked about, but all of the different set of things that you need to do to offer a bank account, a brokerage account, a crypto wallet? That’s really where I see us being able to shine, to give you a toolkit that plugs into the best players in the market, such that you do one integration, and then we can manage that entire suite of obligations for you.

Peter (31:09): It really is such a niche problem, the escheatment problem, but something that is super important. And I’m sure the people that get reminded that they have a four-, five-, or six-figure balance are very, very appreciative when they come on. So anyway, best of luck to you, Allen, and thanks for coming on the show today.

Allen (31:28): Thanks, Peter. Great to see ya.

Peter (31:35): So, best practices in investing has always been to buy and hold. But there should be another piece of the puzzle here, and that is: don’t ignore your account. It must be so disheartening to follow the investing advice of Warren Buffett, or even the crypto hodl crowd, holding your investment for years or even decades, only to have the state force the exchange to sell it out from under you, creating a tax bill on gains you never chose to realize. Allen thinks there’s a legal fight coming over this, and I suspect he is right. It is a striking reminder that rules written in the 1960s to protect consumers can, in a digital asset world, end up doing real harm to the very people they are meant to help. Anyway, that’s it for today’s show. If you enjoy these episodes, please go ahead and subscribe, tell a friend, or leave a review. And thanks so much for listening.