Product: Checking or savings account

I am writing to request a review of a hold on {$780000.00} of my funds that has lasted over one month without accurate explanation from my bank, TCF Bank, nor with any regard to my repeated requests for information. 

Please note that I recognize the authority of banking institutions to conduct investigations. I suspect, however, that this authority requires a documented basis for a banks actions. Presumably, this authority also requires accurate communication with clients whose funds have been held. 

On the morning of Tuesday, XX/XX/XXXX, I signed into the TCF Bank online portal for my business ( XXXX XXXX XXXX ) and noticed a large negative balance in one account and {$0.00} balances in two other business accounts as well as my personal accounts. On further investigation, I noted that large holds had been placed on these accounts. In fact, the amount of one hold corresponded to a far larger value than I had ever kept in the affected account. 

XXXX XXXX takes care of over 25 vulnerable adults in XXXX XXXX, employing XXXX hard-working staff members in our mission to provide excellent care to clients with behavioral health needs. Any disruption of our ability to pay vendors or employees carries the very real consequence of degrading or interrupting our ability to take care of some of the neediest citizens of Minnesota. 

Shocked at the {$0.00} bank balances, I spoke to the manager of my local TCF Bank branch, Ms. XXXX XXXX. After I explained the situation, Ms. XXXX placed a phone call to an unnamed woman, Lets see how much of the funds we can release to you. After the call, Ms. XXXX said that SBA concerns were the reason for the hold and that she could not offer further information to us. She said that the woman with whom she had communicated is not a customer-facing contact and that MsXXXX XXXX comments were the only information we would receive. 

Contemporaneously, I instructed a staff member, XXXX XXXX, to call the TCF Business Banking help line where we were told that we would be called back with information regarding the holds. We never received a return call. 

Notably, in XX/XX/XXXX and in XX/XX/XXXX, I received first-draw and second-draw XXXX loans, respectively, from the United States Small Business Administration ( SBA ) via TCF Bank. While I applied for the first-draw XXXXPP loan independently, I hired a CPA to advise me on the use of PPP funds ; to calculate the amount of money to be forgiven by SBA ; to apply for forgiveness of the first-draw PPP loan ; and, finally, to apply for a second-draw PPP loan after an analysis of my companys financials. I note that TCF Bank reported that our first-draw PPP loan has been forgiven and, presumably, that TCF was reimbursed by SBA after proffering this report. 

Later on Tuesday, XX/XX/XXXX, I spoke with a TCF call center representative who attempted to contact an individual who was purportedly responsible for the hold. This representative said she had attempted to call a non customer-facing [ female ] contact whose details she could not divulge. The representative asked for my phone number and said I would receive a follow-up call. I never received a return call. 

On Thursday, XX/XX/XXXX, I received multiple letters ( see attachments ) from TCF Bank which in substance stated that the bank had placed a hold on our funds because they anticipate receiving a request to return the funds to the originator. This statement was very confusing, as many of the held funds were solely the property of myself and/or XXXX XXXX. Further, when adding the amount of funds seized ( see Table 1 ) and the additional negative balance created by TCFs large holds, I tabulate {$1.00} XXXX to which TCF Bank claims to have a right. This large sum has no relationship to any loan or other transaction I have performed with TCF Bank. 

The letter I received advised me to call TCF Fraud Protection Services ( XXXX option # 1, option # 4 ). I did this and spoke with a representative named XXXX. I learned that, while the letter suggested we should call his department, that XXXX department in fact had no knowledge of the reason for the holds and that his department was not in fact the correct department to call. XXXX placed my team members and I on hold and claimed to have made a series of phone calls. He stated that he was unable to reach the person responsible for the holds, who he named as TCF Sr. Manager and Vice President XXXX XXXX. He transferred me to her voicemail where we left a detailed voice message requesting that we be called back. While I can not be sure, I suspect that Ms. XXXX is the individual who was unable to be reached by prior TCF staff members throughout the week of XX/XX/XXXX. 

Based on the lack of communication we had observed from Tuesday, XX/XX/XXXX through Thursday, XX/XX/XXXX, I instructed a staff member to send an email to TCF Sr. Manager and Vice President XXXX XXXX ( included ; see email transcript dated XX/XX/XXXX ) and to copy other senior TCF staff with whom we have corresponded. Ms. XXXX called in response to this email at XXXX XXXX on Thursday, XX/XX/XXXX. While I could not join, this call included two XXXX XXXX staff members. 

In this call, XXXX XXXX explained that the letters we received were in fact inaccurate - she stated that her department doesnt send out those letters - and that the holds had been placed as part of an investigation from a governmental agency ( whereas the letters did not make this claim see attachments ). XXXX XXXX stated that she runs the office associated with fraud investigations and was aware of the holds that had taken place on our accounts. 

Shockingly, Ms. XXXX said she was unsure if the amounts placed on hold were the amounts requested by the unnamed governmental agency. She said that sometimes the hold system places a hold on all funds but that she would look into the matter later on the evening of Thursday, XX/XX/XXXX. Even now, on Monday, XX/XX/XXXX we have not received updates on this issue from TCF Bank or Ms. XXXX XXXX despite a series of follow-up emails to Ms. XXXX ( see email transcripts ) from my organization and a lawyer. I remain unaware whether the sum of the holds from Ms. XXXX and TCF Bank has any substantive basis. 

It appears that TCF Bank indiscriminately placed a hold on the funds of my firm and on my personal funds, ostensibly responding to an investigation request that I suspect has never existed. I humbly ask that your organization examine these practices and ensure that Ms. XXXX department and TCF Bank exercise greater responsibility when seizing customer funds in the future. I do not believe it should require weeks and untold phone calls to learn whether a hold on an account has an accurate basis. 

To summarize, I have the following complaints and areas for exploration that I believe would benefit from the attention of a governmental regulator in order to protect business owners from organizations such as TCF : The total balance of outstanding loans I had with TCF Bank at the time of the freeze on my funds was approximately {$410000.00} in a second-draw PPP loan. Our first-draw PPP loan in the amount of {$370000.00} had been forgiven. However, across my business and personal accounts, TCF Bank has seized {$780000.00} and somehow claims that it is owed an additional {$740000.00} beyond this amount. Effectively, the actions of TCF suggest that I owe them over {>= $1,000,000}. This is far more than the balance of loans I have ever sought from TCF Bank. Neither Ms. XXXX XXXX nor any other TCF representative has explained this peculiar accounting. 

TCF Bank has been on a long campaign of expansion, and I understand that they may be one of the largest institutions in the United States by size. In fact, I understand that TCF is purchasing another national bank just this XXXX. My experiences suggest that TCF - or at least the department run by Ms. XXXX and the department responsible for explaining holds to customers - has been taxed beyond its capacity. This is clearly demonstrated by Ms. XXXX repeated offers to communicate, and subsequent failures to do so ( see email transcript ) ; by the weeklong inability of TCF staff members to get in contact with XXXX XXXX ; by the inability of the fraud department to mail an accurate letter to me ; and the uncertainty of Ms. XXXX regarding the amount of funds held by her department, amongst other things. I hope that my complaint may help the bank assess its staffing levels and competencies at its current size. I further hope my complaint encourages a more careful examination of any future TCF expansion. 

Finally, I must raise the question of whether my identity as an XXXX American businesswoman has impacted the actions of TCF. In early XXXX, the manager of my local TCF Bank branch, XXXX XXXX, informed me, in an apparent attempt at a compliment, that her branch team had prepared a presentation about my company for a TCF district meeting. She said that XXXX XXXX exemplified successful minority businesses in our city of XXXX XXXX, MN. This story gives me pause, as at no time did TCF reach out to us to learn about our business or our willingness to be put on display for the benefit of Ms. XXXX branch. Indeed, the basis of her presentation could only have been an arbitrary review of our account activity by Ms. XXXX. Second, this story suggests that TCF Bank is monitoring the activity of minority account holders solely based on our identity. It is not hard to imagine that this sort of discriminatory review of minority accounts led to the inception of TCFs poorly-documented investigation and the holds placed on my funds. 

I am ready to show any requisite evidence regarding our PPP application as well as my companys substantial payroll expenditures. Indeed, my payroll has grown in XXXX as we offered our staff hazard pay and increased hourly wages to maintain safe staffing levels during this pandemic. I do not write you with any pleasure but out of desperation in the face of extraordinary behavior from TCF Bank.