Product: Money transfer, virtual currency, or money service

Formal Complaint Against Block , Inc. ( Square ) Systemic Violations of Federal Law, Defiance of CFPB Orders, & Request for DOJ Intervention ( File No. XXXX XXXX ) Dear CFPB Office of Consumer Response, I am filing this formal complaint against Block, Inc. ( Square ) for systemic violations of federal consumer protection laws, including the Electronic Fund Transfer Act ( EFTA ), UDAAP standards under the Consumer Financial Protection Act ( CFPA ), and CFPB Consent Order 2025-CFPB-0001. Square has withheld {$4900.00} of my business funds since XX/XX/XXXX without evidence, relying solely on boilerplate Terms of Service ( ToS ) clauses and fabricated claims of high-risk activity. This conduct mirrors violations addressed in recent CFPB and multi-state enforcement actions, confirming Squares status as a repeat offender requiring urgent intervention. 
I. Squares Unlawful Conduct Indefinite Fund Retention Without Evidence Square terminated my account on XX/XX/XXXX, citing high-risk activity but provided no transaction-specific risk assessments or compliance documentation. 

Violates Regulation E ( 12 C.F.R. 1005.11 ) : Failed to investigate alleged chargebacks within 10 days or issue provisional credits within 45 days. 

Weaponization of Terms of Service Square claims its ToS authorizes arbitrary account closures and fund holds. As established in CFPB v. XXXX ( XXXX ), ToS can not override federal rights under 15 U.S.C. 1693l ( a ).

Documentation Suppression Square alleges 47 chargebacks but provides no transaction IDs, bank rulings, or merchant notifications, violating CFPB Bulletin XXXX ( documentation standards ). 

Defiance of CFPB Consent Order 2025-CFPB-0001 Square continues prohibited practices : indefinite holds, ToS abuse, and failure to comply with EFTA.

II. Legal Basis for Enforcement & DOJ Referral A. Federal Law Violations EFTA ( 15 U.S.C. 1693 ) : Square failed to resolve errors or release funds within mandated timelines.

UDAAP ( 12 U.S.C. 5531 ) : Unfair : Indefinite holds harm small businesses irreparably.

Deceptive : Misrepresenting ToS as justification for federal non-compliance.

Fraudulent Practices ( 18 U.S.C. 1345 ) : Withholding funds while suppressing evidence constitutes interstate fraud.

B. DOJ Referral Request Under 12 U.S.C. 5564, I request the CFPB refer this matter to the DOJ for : Prosecution of fraudulent practices under 18 U.S.C. 1345.

Investigation of potential RICO violations ( 18 U.S.C. 1962 ) due to Squares nationwide pattern of harm. 

III. Demands for Relief Immediate Remediation : Release {$490000.00} + statutory interest under 15 U.S.C. 1693m within 14 days.

Documentation Disclosure : Compel Square to produce : Transaction IDs, bank rulings, and merchant notices for all 47 alleged chargebacks.

Internal risk assessments and compliance audits justifying indefinite holds.

Systemic Reforms : Amend ToS to comply with CFPB Consent Order 2025-CFPB-0001 14 ( b ).

Mandate third-party audits of Squares compliance program.

DOJ Referral : Escalate for prosecution of fraudulent practices impacting interstate commerce.

IV. Strategic Framing to Preempt Squares Defenses Invalidity of ToS Defenses : Per CFPB XXXX XXXX XXXX XXXX ( XXXX ), courts void ToS clauses that waive federal rights. 

Arizona law ( A.R.S. 47-2302 ) requires ToS terms to be conscionable and reasonably communicated. 

Systemic Harm Precedent : Cite DFPI/48-State Consent Order XXXX, where Square admitted identical violations in 48 states.

Fraudulent Intent : Squares suppression of evidence violates 18 U.S.C. 1001 ( false statements to agencies ).

V. Conclusion Squares conduct reflects a deliberate scheme to exploit small businesses through ToS abuse and evidence suppression. The CFPB must act decisively to enforce its Consent Orders, recover unlawfully withheld funds, and refer this matter to the DOJ to halt Squares nationwide harm. 



Respectfully, XXXX XXXX