In the filing, NFID alleges that Prime Trust discovered in December 2021 that it couldn't access some customer wallets, and so "purchased additional digital currency using customer money from its omnibus customer accounts" in order to satisfy withdrawals from said wallets.
Prime Trust reportedly has liabilities of around $82.8 million in fiat currency, plus another $860,000 of digital asset-denominated liabilities. "[Prime Trust] is in an unsafe financial condition and/or is insolvent. Additionally, [Prime Trust's] condition will only progressively worsen as customers continue to withdraw," wrote the regulator.