Yes, Spark combines simultaneously all the negatives of both custodial and noncustodial services. Noncustodial wallets introduce additional risks, in that people can lose their private key or have it jacked by hackers. The tradeoff was sovereignty. Spark retains these risks while introducing surveillance and censorship capabilities, meaning that users gain absolutely nothing for the risks imposed by noncustodianship. It’s worse than traditional bank account, where if your credit card gets jacked you report it to the bank and lose nothing, and if you lose your wallet you can go to the bank and get new cards issued and lose nothing. It is, in my mind, significantly worse in architecture than traditional finance.