If they're going to lock or delete an account (regardless of reason), there should be a requirement that funds are either paid to the benefactor or refunded immediately.
Gofundme partially locked the funds because they don’t know who the benefactor is anymore (according to their official statement). Who gets the money? Does it just go to every person in the city with a semi truck or is it just going to some random person that we hope won’t take the money and run?
As for refunds, I would be willing to bet anyone that donated could go ask gofundme for a refund right now and get their money back. Sure they could mass refund everyone right away, but it seems like a bad policy to do a mass refund whenever the benefactor becomes unclear. It would be incredibly annoying to fund a huge project and the point of contact for the project quits and for all the funding to instantly get refunded.
It's a problem that is suspiciously one-sided, at least as far as 404ing/disabling the linked page, locking the account, and pausing donations while being resolved.
There are clear definitions, regulations, and penalties for operating as a dollar holding/ transferring financial institution.
Especially since the percentage paid as a fee makes it essentially a defaulted account, or at least a service not provided and funds not returned.
These types of donation accounts have a long history at brick banks of helping those in need (while taking a hefty percentage off the top). It's not a new idea.
I suspect it's more likely this isn't lack of regulation, so much as a loophole or stretched legal definition. Maybe someone here is familiar with their regulatory classification. You don't launch something like this without reasonably ensuring the feds aren't coming after you.