Banks commingle (or pool) customer funds in the ordinary course of business for regular deposit accounts. Note: Education is key. The narritive that commingling funds is somehow only in crypto is a false narritive. Every bank commingles every deposit to get overnight interest from the Federal Reserve system. Thats how banks make profit. However in banking, this is legal, regulated. With Clarity and Market Structure this same regulation will apply to digital asset exchanges. Here's a clear breakdown: Regular Bank Deposits When you deposit money into a standard bank account, your funds are pooled with those of other customers. The bank doesn't keep your specific dollars separate in an individual vault or sub-account labeled just for you. The bank uses these pooled deposits to make loans, invest, etc., under fractional reserve banking rules. This is how banks create credit and earn money (via the spread between deposit interest and loan interest). Your deposit is a liability on the bank's balance sheet they owe you the money back (plus any interest), but it's not segregated from other customer deposits. This pooling/commingling is explicitly allowed and essential to the banking system. It's not considered improper "commingling" in the legal sense that implies misconduct.