Sometime in early December 2025, a woman named Stephannie Sloane — a 10-year veteran of the surrogacy industry — logged into her work email and saw a subject line she'd never forget: "Important update regarding company operations."
By the time she finished reading, she knew: Surro Connections was gone. Her employer of a decade had just vaporized overnight, firing all 20 employees via a single email from president Megan Hall-Greenberg and leaving behind a trail of unanswered questions — about where the clients' money went, about surrogates who were already owed payments from escrow, and about an industry that still has no federal licensing requirement, no mandatory escrow insurance minimums, and no systemic early-warning system when an agency starts going under.
Three months later, the Camas, Washington-based agency's collapse is still unfolding. The FBI has reportedly been in contact with former employees. A FOIA request to confirm details of any federal investigation came back empty. And Hall-Greenberg — who had been sued twice by American Express for unpaid credit card debt totaling more than $100,000 in 2024 and 2025 — has not publicly responded.
What Actually Happened
The signs were there before the end. In November 2025 — a full month before the closure — some surrogates stopped receiving their monthly escrow payments on time. Staff at Surro Connections raised it internally. Payments came through eventually, but the same problem resurfaced in December. When surrogate coordinators tried to reach Hall-Greenberg directly, she went silent.
On December 5th, after days of no response, the termination email arrived. Employees were told to refrain from making any statements on behalf of the company if contacted by clients or surrogates. That left the people whose money was sitting in the agency's escrow accounts — intended parents and surrogates alike — with no official point of contact and no clear answers about their funds.
"It was kind of a disaster. I think part of me hoped it was a mistake. Part of me hoped she was going to come out of hiding and be like, 'Just kidding.' I just kept hoping that something good would come on the other side."
— Stephannie Sloane, former Surro Connections coordinator, speaking to the Camas-Washougal Post-Record
The New York Times, which reported on the closure in December, noted that Surro Connections most likely held millions of dollars in client funds — but carried only $100,000 in insurance coverage. That gap is the core of the problem.
One Person Approved Every Payment
Sloane told reporters that she had assumed payment approvals from escrow were handled at the manager level. She only learned after the closure that Hall-Greenberg alone had authority over all outgoing payments. No secondary approver. No dual-control requirement. Just one person with access to every dollar.
Michael Chally, executive director of Northwest Surrogacy Center in Portland and a decade-long industry veteran, was direct about what this means: reputable agencies should not operate this way, and that structure should be a disqualifying red flag for anyone evaluating an agency.
"No one person should be in charge of transactions. Ultimately, any outside escrow agency or agency that's holding money internally should be able to supply things like their insurance to anyone who requests it. Anyone who is uncomfortable talking about these things with a potential family or surrogate — that's a red flag."
— Michael Chally, Executive Director, Northwest Surrogacy Center
An Industry Without a Regulatory Floor
This isn't a one-off story. Chally noted that Surro Connections is the second major US surrogacy agency to close in the past two years. The industry remains largely unregulated at the federal level — there's no licensing requirement, no mandatory insurance minimums, no auditing standard for escrow accounts. Individual states have varying levels of oversight: Washington passed the Uniform Parentage Act in 2019, which established legal protections for surrogacy contracts and parental rights, but that law says nothing about how agencies manage client funds.
Industry groups do publish standards and best practices. The problem is that following them is voluntary, and bad actors don't self-identify before a crisis. Chally said legislation is possible depending on whether the industry demonstrates it can self-regulate — but so far, the track record on that front is shaky.
Based on industry expert guidance and what we know about the Surro Connections collapse, these are the warning signs that should make you pump the brakes:
- Agency is unwilling to share escrow insurance documentation on request
- One person has sole authority over escrow payment approvals (no dual control)
- Agency holds funds internally rather than using a third-party escrow company
- Insurance coverage is significantly lower than total funds managed
- Agency avoids direct questions about financial structure or accounting practices
- Payments to surrogates are consistently late or require follow-up
What This Means If You're Currently in a Journey
If your agency is the one holding your escrow funds — not an independent third-party escrow company — it's worth understanding exactly what protections exist if the agency were to close tomorrow. The honest answer at most agencies is: less than you'd hope. That's not cause for panic, but it is cause for a direct conversation with your agency coordinator about how funds are protected, how much insurance coverage exists, and who has authority over outgoing payments.
The surrogate community has been circulating this issue in private Facebook groups and forums for months. The anger is real. But so is the practical advice coming out of those conversations: know your agency's escrow structure before you're in the middle of a pregnancy.
🤰 For Surrogates
Your escrow money is yours — but "held in escrow" is not a guarantee if the agency managing that escrow doesn't have adequate insurance or financial controls. Before signing with any agency, ask directly: Is escrow held by a third-party company or internally by the agency? What insurance covers those funds? Who approves outgoing payments, and is there a second approver? A reputable agency will answer these questions without hesitation. If they hedge, that's information.
If you're currently in a journey and payments are late — even by a few days — document everything and escalate immediately. Late payments are one of the earliest warning signs. Don't wait for an email with "Important update regarding company operations" in the subject line.
👨👩👧 For Intended Parents
You're often the ones funding the escrow account, which means you have the most direct financial exposure if an agency collapses. Ask to see proof of the agency's escrow insurance — specifically what it covers (employee theft, owner fraud, cyber incidents) and for how much. The $100K policy at Surro Connections on an account reportedly holding millions is the textbook example of a mismatch that should have been caught in due diligence.
Some IPs are now specifically choosing agencies that use independent third-party escrow companies rather than holding funds in-house — even if it costs slightly more. That extra layer of separation is worth asking about.
SurroScore tracks 200+ agencies. See how programs in your state compare — including what we know about their financial structures.
Browse Agency Profiles →What Happens Next
The FBI's reported involvement suggests this may go beyond a garden-variety business failure. Hall-Greenberg's prior financial troubles — two separate American Express lawsuits for unpaid debt, one in 2024 and one in 2025 — are a matter of public court record. Whether there's criminal exposure beyond civil liability isn't yet known; federal investigations in this space tend to move slowly.
For the broader industry, the more immediate question is whether this second major agency closure in two years prompts any real push for reform — mandatory escrow insurance minimums, third-party audits, dual-control requirements for payment approval. Chally and others in the industry are calling for exactly that. Whether it happens through self-regulation or eventually through legislation, nobody knows yet.
What we do know: the people who got hurt in the Surro Connections collapse did nothing wrong. They trusted a licensed business with their money and with the most important journey of their lives. The industry owes them — and future surrogates and intended parents — better structural protections than currently exist.