Consumer complaint received 2025-02-21 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Deposits and withdrawals
Company: BOK FINANCIAL CORP
State: OH

Complaint narrative:
Subject : Formal Complaint Against XXXX XXXX XXXX  Unlawful Restriction of Funds Dear Consumer Financial Protection Bureau, I am filing a formal complaint against XXXX XXXX XXXX regarding their unlawful restriction of funds after they were transferred to my XXXX XXXX  business account, made available, and partially used for business transactions. XXXX XXXX XXXX  actions may constitute a violation of banking and contract laws, including Regulation CC, Uniform Commercial Code ( UCC ) provisions, and Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) violations. 

Case Summary On XX/XX/2025, my company, XXXX XXXX XXXX XXXX closed a real estate transaction. 
On XX/XX/2025, a wire transfer was sent from the sending partys bank, XXXX XXXX XXXX account to my XXXX XXXX business account in the amount of {$730000.00}. 
Upon receipt, XXXX XXXX marked the funds as available, and I proceeded to use them for legitimate business transactions ( XXXX in total ). 
On XX/XX/2025, XXXX XXXX suddenly restricted my account, citing that my account was outside their risk tolerance. They refused to provide any clear time frame or legal basis for withholding my funds. 
It was later found out, XXXX XXXX XXXX had since placed a hold harmless restriction on the funds after they already sent the outgoing wire to XXXXXXXX XXXX In turn, causing XXXXXXXX XXXX to restrict my account, preventing me from accessing them, despite the fact that the transfer was completed, the funds were made available, and I had already begun using them. 

There was no fraudulent or suspicious activity that took place. All actions and wire transfers, for both the sending party and receiving party, were compliant with the law, ethical and authorized. A hold harmless was completely unnecessary. XXXX XXXX XXXX also called my company, XXXX XXXX XXXX XXXX as a confirmation

call before any wire transfers were sent Legal Violations and Concerns 1. Breach of Funds Availability Rules ( Regulation CC Violation ) Once XXXX XXXX XXXX transferred the funds and they were made available to me, the bank no longer had control over them unless fraud, an error, or a legal order was involved.

Restricting the funds after they were transferred may constitute an unlawful act under Regulation CC ( Expedited Funds Availability Act ).

2. Unauthorized Reversal or Hold ( UCC Violation ) UCC 4A-404 : Once a bank accepts and executes a payment order, it must allow the funds to remain available unless there is a valid legal reason ( such as fraud or a court order ). 
If the bank attempts to recall or restrict the funds without prior agreement or legal basis, this could constitute a UCC violation.

Since I already used part of the funds, this sudden reversal has created financial harm, which may warrant further legal action.

3. Unfair or Deceptive Banking Practices ( UDAAP Violation ) If XXXX XXXX XXXX  provided me with false or misleading information about the availability of my funds and later imposed a restriction, this could be considered an Unfair, Deceptive, or Abusive Act or Practice ( UDAAP ) under CFPB regulations. 

Exceptions Where the Bank May Have Authority The only valid reasons XXXX XXXX XXXX  may have for restricting the funds would be : If the funds were transferred due to fraud or an error ( such as a duplicate transfer or unauthorized transaction ).

If the bank was ordered to do so by law enforcement or a court order. 
If there was a pre-existing agreement that allowed them to impose a hold harmless restriction after the transfer ( which is highly unlikely in this case ). 

Requested Action from the CFPB I request that the CFPB investigate this matter and take action to ensure that : 1. XXXX XXXX XXXX removes the unlawful hold on my funds and allows me to access them immediately.

2. XXXX XXXX XXXX provides written justification for why they imposed a hold after the funds were already released.

3. Regulatory penalties or corrective actions are enforced if XXXX XXXX XXXX is found to be in violation of federal banking laws. 

This situation has caused unnecessary financial harm to my business, and I expect immediate action to rectify the issue. Please confirm receipt of this complaint and advise on the next steps.

Company response to consumer: Closed with explanation