Consumer complaint received 2024-04-05
Product: Money transfer, virtual currency, or money service — Mobile or digital wallet
Issue: Trouble accessing funds in your mobile or digital wallet — 
Company: Paypal Holdings, Inc (CA)

Dear CFPB XXXX XXXX, I'm XXXX XXXX XXXX and XXXX permanently Limited my account on XX/XX/2023 without any notification either via mail or text message. 
I realized this days later when I logged into my account and contacted XXXX XXXX team who informed me that the action was automated and that there is nothing that could be done but wait for 180 days to withdraw my funds if there won't be any reversal or chargeback. 
I was quite distraught by that information and I felt helpless. 

I took time to go over their User Agreement Police which is quite long to just see what I might have done wrong to warrant such a cold permanent limitation and I could not tell what user agreement policy I had breached! 

I also came across this policy under their user agreement and I will quote it below : Holds, Limitations, and Reserves What are holds, limitations, and reserves? 
" Under certain circumstances, in order to protect XXXX and the security and integrity of the network of buyers and sellers that use the XXXX services, XXXX XXXX take account-level or transaction-level actions. Unless otherwise noted, if we take any of the actions described here, well provide you with notice of our actions, but we retain the sole discretion to take these actions. To request information in connection with an account limitation, hold or reserve, you should visit the XXXX XXXX or follow the instructions in our email notice with respect to the limitation, hold or reserve. Account holds or limitations XXXX impact your ability to move funds to or from your XXXX XXXX account '' XXXX. By neglecting to provide me with a NOTIFICATION OF ACCOUNT TERMINATION in-form of an email or text is a clear violation of your User agreement as clearly stated in the above quote. 
I had to log in to the account days later to see the red header at the top which stated my account was permanently limited and without precise reason as to which violation of terms I committed. 
To this day, XXXX has never FORMALLY notified me of any hold or restriction. 
The fact that you haven't given me enough information about why the money in my account was put on hold or how to get the cash released is also a breach of your own agreement. 

XXXX. XXXX. Illegally withholding money for more than 180 days while claiming that I breached acceptable user policy and NOT notifying the recipient of the policy violationa move you intend to utilize as a " License to Punish me as a user, withhold my funds and Keep it for yourself '' A company cannotor at least shouldn'tjust state " REASONS '' and seize a user 's funds and walk away with it! It is a completely distinct thing to terminate a user from your platform and say, " We no longer want your kind in here and we are keeping all your money to ourselves. Please take your business/money elsewhere. '' This is a violation of the rules you have set and something which requires to be addressed in a court of law. 

XXXX. Not releasing the hold on the money in my XXXX account as directed by your user policy, despite the fact that I have never experienced a chargeback, dispute, or fraudulent claim up to this point is breach of your own policies. It is not sufficient for a business like yours to simply have a duty of care and then breach the standard of conduct expected of XXXX - that conduct must also cause the damage that the claimant or user has suffered and If the risk exposure is greater to your business, then prove this in a court of law why you can close a users account without notice then proceed to keep their funds! 

Your User Agreement States : Court Orders, Regulatory Requirements, or Other Legal Processes If we are notified of a court order or other legal process ( including garnishment or any equivalent process ) affecting you, or if we otherwise believe we are required to do so in order to comply with applicable law or regulatory requirements, we may be required to take certain actions, including holding payments to/from your XXXX account, placing a reserve or limitation on your XXXX account, or releasing your funds. We will decide, in our sole discretion, which action is required of us. Unless the court order, applicable law, regulatory requirement or other legal process requires otherwise, we will notify you of these actions. We do not have an obligation to contest or appeal any court order or legal process involving you or your XXXX account. When we implement a hold, reserve or limitation as a result of a court order, applicable law, regulatory requirement or other legal process, the hold, reserve or limitation may remain in place longer than 180 days. 



XXXX : Most government-initiated fund XXXX necessitate formal notification to the target, preferably after the facts are proved, and a chance provided to challenge the XXXX through administrative and legal channels. 

This is because of the " XXXX amendment ''! 
There would have been an independent notice to the targets if there was any possibility that the government was requesting these actions. 
It is illegal and against your user agreement to hold or keep money after 180 days after informing users of a limitation and incases where there has been no cases of Chargebacks, disputes or loss to XXXX. This should be challenged in court or investigated by regulatory agencies such as the Federal Reserve Assistance or the XXXX XXXX XXXX XXXX ( CFPB ). 

I am respectfully requesting that the hold on my funds/account be lifted. I am not necessarily requesting that my account be re-opened or allowed to continue to use the XXXX services. 
I have previously requested a review/appeal of my case which was denied. Although I still disagree with the decision to deny my appeal, I'll abide by your take on it. However, holding onto my funds for the past 180 days for a non-fraudulent violation of XXXX XXXX XXXX XXXX is excessive, punitive abuse of power and contrary to the state laws of CA. 

I understand PayPals need for holding funds for credit card and chargeback purposes, however a review of my account history for the last year or XXXX months it has been limited permanently will reveal this never happened to me. 
I am also addressing my grievances with the following relevant federal agencies below : XXXX www.federalreserveconsumerhelp.gov/complaintinfo.cfm? info XXXX https : XXXX XXXX https : //oag.ca.gov/contact/consumer-complaint-against-business-or-company If the issue is not addressed by those agencies, I'll file a court case with my attorney, obtain a subpoena and let XXXX prove in court what breach of violation I committed in court. 
I have a degree in XXXX and I know where my concerns with XXXX stand as of today. I understand my rights as well as XXXX terms which we have gone through with my attorney who advised me to arbitrate with government agencies first before we proceed with the court case. 
Let those agencies determine if XXXX is operating within the law, or simply abusing power because XXXX User Policy and terms can not be used as a " permit '' to steal from your users. '' I am simply seeking a resolution that is fair and in the best interest of both parties. 


Thank you for your time and Looking into this matter. 

Best regards, XXXX.