Did they write anything up?
From what I have seen I do not think that FTX held itself out to formally be a "segregated accounts company" and the example CoffeeZilla uses of a bank is a bad example because that is exactly how banks operate. i.e. the problem with FTX was that they informally held themselves out to be a segregated accounts company but formally operated like a bank on a first-come-first-served basis.