Consumer complaint received 2024-07-10
Product: Checking or savings account — Checking account
Issue: Managing an account — Deposits and withdrawals
Company: JPMORGAN CHASE & CO. (MO)

On XX/XX/year> I deposited a check from my employer, XXXX XXXX, in the amount of {$6500.00}. At that time, Chase Bank placed a large deposit hold on the check, making the first {$220.00} of the check available immediately, and then {$5000.00} would be made available within two business days ( XX/XX/year> ), then the remainder would be made available after 7 business days. Mind you, the remitter of the check was the same as the remitter of my direct deposit to the same account. 

I had no issue with the large deposit hold, and scheduled payments accordingly. These were not big extravagant payments, rather they were my regular bills that I paid each month. My problem is that on XX/XX/year>, Chase Bank extended the hold on my deposit to 7 total business days. This was the day before my payments were scheduled to come out of my account and Chase subsequently returned 4 different payments. XXXX of which causing a returned payment fee of {$40.00} from my credit card issuer. 

Later that same week, I called the number on the hold notice provided to me to ask why the hold was extended. I wasn't provided any reasonable answer and was only told that they were allowed to do so because the check was large. I would disagree with that assessment. 

12 CFR 229.13 ( b ) clearly allowed for my deposit to be placed on a Large Deposit exception hold, however there was no relevant reason for Chase to extend the hold beyond that. I was not a new customer, I did not have a history of overdrafts, redeposited checks, and there were no emergency conditions. This tells me that Chase Bank extended the hold based on a " Reasonable cause to doubt collectability '' as prescribed under 12 CFR 229.13 ( e ). It even says as much on the hold notice that was sent to me after they decided to extend the hold. However, when I spoke to Chase about this during my phone call, not only could they not articulate any reason why they had a " reasonable doubt '', but the representative even told me that the only reason the hold was extended was because it was a large deposit and that it was unusual for me to deposit checks into my account. 

Now, I'm not an attorney, but Reg CC already has rules and provisions for placing a hold on a Large deposit. Chase blatantly chose to ignore those rules and provisions and extended the hold without a " Reasonable cause to doubt collectability, '' as defined in 12 CFR 229.13 ( e ) ( 1 ). To quote from the reg directly " Reasonable cause to believe a check is uncollectable requires the existence of facts that would cause a well-grounded belief in the mind of a reasonable person. '' Well, let me tell you the facts. The fact is that the check being deposited was from my employer, and the remitter on the check matched the name on my employer direct deposit that was deposited into the same Chase account every two weeks. Another fact is that the agent I spoke to told me the check was held due to it being a " large check. '' There are no other facts to this matter, and the check being " large '' is not a reason to have doubt that the check would not be paid. There was zero legitimate reasons to have " reasonable cause to doubt collectability. '' As a result of Chase 's practice to baselessly extend holds under the guise of " reasonable cause to doubt collectability, '' I, the consumer, have been harmed. And I would imagine other consumers have been harmed. As I previously stated, I made arrangements to pay certain bills after the Large Deposit hold was set to expire, and because the hold was baselessly extended, I had payments go unpaid and were returned with a fee. 

I recently went into my local Chase Bank and brought this matter up. I requested that they provide a {$40.00} credit to my Chase account for the fee I incurred from my credit card issuer. The branch associate said that he was unable to refund the fee but would file a complaint on my behalf. I agreed that this was satisfactory. I was just contacted about an hour ago by a representative named XXXX from their escalation team. He told me that the branch associate was correct that they dont refund fees assessed from third parties, and that it was against their policy to refund fees assessed from third parties. I explained to XXXX that I believed their practices for extending holds was baseless, explained the reason why I believed they were baseless, and asked that my argument be considered. XXXX stated that he would collect my feedback, but that ultimately nothing would likely come of it, i.e. my request for a {$40.00} account credit would not be granted. At that time I let XXXX know that I would be filing a CFPB complaint today regarding the matter. I was honestly very surprised that there was no further escalation to my complaint at that point, but hey, whatever, if they want me to put it in writing and send it to their primary regulator, that is their prerogative.