Product: Money transfer, virtual currency, or money service

Subject : Complaint against Block , Inc. ( Square ) - Systematic EFTA/UDAAP Violations and Deceptive Practices To : Consumer Financial Protection Bureau ( CFPB ) I am filing this complaint against Block, Inc. ( operating as Square ) regarding their systematic violations of federal consumer protection laws and deceptive practices in withholding my funds of {$4500.00}. 

# Chronological Timeline of Events : - XX/XX/XXXX : XXXX XXXX merchant account as " XXXX '' - XX/XX/XXXX : Square deactivated account and began withholding funds - XX/XX/XXXX : Initial inquiry about fund release ( Case # XXXX ) - XX/XX/XXXX : Square promised next-day resolution ( Case # XXXX ) - XX/XX/XXXX : Square claimed to " lift protective hold '' but transfers remained blocked - XX/XX/XXXX : After failed transfers, Square created new requirements ( Case # XXXX ) - XX/XX/XXXX : Square made a " final decision '' without proper justification # Systematic EFTA and UDAAP Violations : 1. *EFTA/Regulation E Violations* : - Extended fund hold exceeding 2 years without valid justification - No documented evidence provided for alleged " excessive chargebacks '' - Failure to implement proper error resolution process - Non-issuance of provisional credits as mandated by Regulation E 2. *UDAAP Violations* : - Unfair : Extended hold beyond industry standard 90-180 days - Deceptive : False promises about fund release - Abusive : Using Terms of Service to override federal consumer protection laws # Regulatory Context and Precedent : 1. *Direct Connection to CFPB Consent Order* : - Recent CFPB Consent Order ( File No. XXXX ) addressed identical violations- CFPB ordered XXXX to XXXX {$170.00} XXXX ( {$120.00} XXXX in consumer redress, {$55.00} XXXX penalty ) - My case demonstrates continued non-compliance despite enforcement action 2. *State Regulatory Actions* : - 48 state financial regulators imposed {$80.00} million fine for similar violations - Multiple state Attorneys General currently investigating Block 's practices - Pattern indicates systematic regulatory non-compliance # Evidence of Systematic Evasive Practices : 1. **Documented Communication Trail** : - Multiple case numbers demonstrating repeated unfulfilled promises- Written confirmation of " lifted hold '' contradicted by blocked transfers - Consistent pattern of denying access without providing evidence - Practice of deflecting disputes to banks, then denying resolution 2. *Legal Framework Violations* : - Improper reliance on Terms of Service to override federal law - CFPB guidance explicitly prohibits using Terms of Service to circumvent consumer protection laws- Violation of EFTA/Regulation E mandated timeframes - Non-compliance with UDAAP requirements for clear communication # Detailed Evidence Requirements and Documentation Demands : XXXX. *Chargeback Documentation Requirements* : - Complete list of each alleged chargeback with dates, amounts, and specific reasons - Transaction IDs and time-stamped dispute notices- Verification from issuing banks and card networks ( Visa/Mastercard ) - Evidence of compliance with Regulation E 's 45-day investigation requirement - Final outcomes of all disputes and chargebacks 2. *High-Risk Designation Evidence* : - Specific transactions flagged as high-risk with detailed explanation - Risk assessment procedures and documentation - Justification for extended hold beyond industry-standard 90-180 days - Evidence supporting ongoing security concerns - Compliance documentation with federal regulations regarding fund holds 3. *Communication and Account History* : - Complete record of all attempted communications - Timeline of account review and decision-making process - Documentation of resolution attempts- Records of all customer service interactions- Evidence of proper notice before account deactivation # Consumer Impact : 1. *Financial Harm* : - {$4500.00} withheld for over 2 years - Multiple failed transfer attempts despite " lifted '' hold - Ongoing financial hardship from fund inaccessibility 2. *Pattern of Deception* : - Documented unfulfilled promises - Contradictory actions following written assurances - Systematic failure to provide evidence or explanation Given Block 's recent admission of compliance issues in SEC filings and the pattern of violations identified by multiple regulatory bodies, I request CFPB 's thorough investigation of these ongoing systematic violations. This case demonstrates the need for regulatory intervention beyond individual resolution, particularly in light of Block 's continued non-compliance despite recent enforcement actions.

I request the following fair resolution : 1. Immediate release of my withheld funds ( {$4500.00} ) 2. A direct, specific response addressing all documentation requirements outlined above 3. Written confirmation of compliance with EFTA and Regulation E requirements 4. Clear timeline for fund release if any legitimate holds exist I expect Square to provide a straightforward response with specific documentation rather than evasive replies citing general policies. 

XXXX XXXX XXXX XXXX XXXX, XXXX CA XXXX ( XXXX ) XXXX XXXX XXXX