Consumer complaint received 2025-11-14 00:00:00
Product: Checking or savings account — Checking account
Issue: Closing an account — Funds not received from closed account
Company: PNC Bank N.A.
State: FL

Complaint narrative:
CFPB Complaint Update New Developments as of XX/XX/XXXX I am submitting this update because PNC Banks conduct has escalated significantly since my original CFPB complaint on XX/XX/XXXX. Multiple new contradictions, federal law violations, and retaliatory actions have now been confirmed by PNCs Executive Office representative during a recorded call on XX/XX/XXXX. 

XXXX. XX/XX/XXXX PNC told regulators the account was still under further review PNCs written response dated XX/XX/XXXX stated : The account was not closed The Treasury funds remained in a suspense account PNC required more time for internal review This communication was submitted after the funds had already been fully verified and flagged as PAID through XXXXXXXX 

XXXX. XX/XX/XXXX All accounts were suddenly closed During the XX/XX/XXXX call, PNC Executive Office representative XXXX confirmed : All of your accounts were closed on XX/XX/XXXX. 
No written notice was provided in advance and no permissible justification was offered while a CFPB investigation was ongoing. 

XXXX. New and alarming development PNC XXXX be attempting to send the funds back to the Treasury On the same call, XXXX stated : It looks like were possibly returning those to the Treasury. 
This represents conversion of federal funds, because : The Treasury check has already been verified and PAID through XXXX PNC already received the federal funds The funds were placed in a suspense account Banks can not return cleared funds to Treasury that they already accepted There is no statutory basis under Reg CC, the EFAA, or the UCC for a bank to divert cleared federal funds from the payee back to the Treasury. 

Additional Evidence Admissions by PNC Representative Client relations XXXX on XX/XX/XXXX During a recorded call on XX/XX/XXXX, PNC Executive Client Relations Specialist XXXX made several statements that appear to confirm PNCs unlawful handling of the Treasury funds. These were not opinions they were direct representations of PNCs internal decisions and policies. 
Admission # XXXX PNC acted under the account agreement, not federal law When asked what legal authority allows PNC to return a cleared Treasury check to the Treasury, XXXX stated : We are allowed to return any deposit we see fit under your account agreement. 
However, federal law prohibits this : 12 U.S.C. 4008 ( b ) A bank may NOT use an account agreement to alter, override, or limit federal availability rules under the Expedited Funds Availability Act / Regulation CC.

Therefore, by claiming their account agreement gives them the right to return a cleared Treasury deposit, PNC directly admitted it is not acting under federal law, but instead substituting its own contract in place of federal statute. 
Admission # XXXX PNC claims its account agreement follows federal law When asked whether their actions complied with federal law, XXXX stated : Our account agreement follows federal law, and PNC follows all federal rules and regulations. 
These XXXX statements can not both be true : Federal law says PNC claims Banks must release verified Treasury funds with next-day availability PNC says they may return any deposit we see fit Account agreements may NOT alter federal availability rules PNC claims their account agreement allows returning a paid Treasury check A verified Treasury check can not be re-routed to Treasury PNC states they are possibly returning the funds to the Treasury Her responses confirm PNC is treating the account agreement as if it overrides federal law which is explicitly unlawful. 
Admission # XXXX PNC intends to send cleared Treasury funds back to Treasury XXXX stated : It looks like were possibly returning those to the Treasury. 
A verified check can not be returned unless the bank has already received the funds. 
This confirms : The Treasury check was verified and paid PNC is in possession of the funds PNC is attempting to send the funds somewhere other than to the payee This is not a hold this is conversion of federal funds. 


Together, these statements demonstrate : PNC is imposing its account agreement in place of federal law PNC is withholding and redirecting cleared Treasury funds without authority PNC can not identify any federal statute allowing these actions These are not misunderstandings they are policy-level decisions being communicated by an executive representative.

PNC is knowingly substituting its account agreement for federal law, using that as a basis to withhold and redirect cleared Treasury funds a practice prohibited under 12 U.S.C. 4008 ( b ) and the bank admitted this 5. False statements regarding the maker of the check XXXX asserted that the U.S. Treasury is the maker of the check.

Under UCC 3-103 ( a ) ( 7 ), the maker is the person or entity issuing a promissory note, not the drawer of a Treasury warrant .

Calling the Treasury the maker appears to be an attempt to justify returning cleared federal funds instead of releasing them to the payee.

This reflects a misrepresentation of law to justify withholding federal funds.

6. Illegal POA re-verification and shifting narrative PNCs written notice claimed I stated that I was POA, as though POA were uncertain or unverified. 
However : POA documentation has been on file since XXXX PNC has acknowledged my POA status repeatedly Multiple agents have admitted no change to the account Demanding extra verification for a XXXX already on file months later with no fraud report or update to the account is unsupported and appears retaliatory. 

XXXX. Timeline strongly suggests retaliation Date PNC XXXX XX/XX/XXXX CFPB complaint filed XX/XX/XXXX All accounts abruptly closed XX/XX/XXXX Informed funds may be returned to Treasury 8. Violations now requiring CFPB investigation Based on PNCs most recent admissions, the conduct appears to include : Seizing cleared Treasury funds without statutory authority Claiming discretionary power based on the account agreement to override federal law Attempting to remit cleared funds back to Treasury rather than pay the payee False statements about federal banking law ( Reg CC / UCC ) to justify actions Contradicting statements to regulators vs. statements to the customer Re-verifying POA without cause Freezing and closing unrelated accounts Retaliatory action triggered after filing CFPB complaint Conduct consistent with discriminatory disparate treatment 9. In addition to the legal violations described above, I must respectfully raise a concern that the extreme and unsupported actions taken by PNC appear to reflect differential treatment and heightened suspicion toward me as a XXXX account holder. 
I am not making this claim lightly. My concern is based on the following facts : The account was established for months with no issues Power of Attorney documentation was on record since XXXX without challenge The Treasury check was properly endorsed and verified No fraud report, return, or flag ever existed Yet PNC imposed excessive scrutiny, prolonged holds, extra verification, and then froze and closed every linked account These actions are inconsistent with the federal treatment requirement under the Fair Housing Act and Equal Credit Opportunity Act, both of which prohibit disparate treatment in banking. 
The pattern of conduct raises the question of whether I was treated as though I were a fraud threat despite meeting every legal and procedural requirement, and despite having full, lawful documentation. 
The sequence and severity of actions against me including holding verified government funds, refusing release, closing unrelated accounts, and now attempting to return cleared funds to Treasury reflect a level of suspicion and hostility that would not be reasonably expected for similarly situated non-Black customers. 
I am not alleging facts I can not prove ; rather, I am alerting the Bureau that the intensity and unjustified severity of PNCs actions create a strong appearance of discriminatory treatment.

I am respectfully asking the CFPB to review whether : Internal fraud-risk ratings were influenced by racial profiling ; Race contributed to the decision to hold or seize federal funds ; Account closure and fund refusal were consistent with PNCs treatment of non-Black customers in comparable circumstances. 


If race played any role even indirectly this would implicate not only consumer-protection violations but also federal anti-discrimination violations in banking. 


Importantly, XXXX is not a random front-line call-center agent. She identified herself on the call as an Executive Client Relations Specialist with PNCs Executive Office, speaking while actively reviewing my accounts and the internal investigation notes. She repeatedly stated she was relaying what PNCs internal teams were looking into and what PNC was doing with the funds. In that capacity, her statements are official communications of PNC Bank, not personal opinions. PNC should not be permitted to later characterize these admissions as a mere misstatement by an uninformed employee ; they reflect how PNCs Executive Office is actually handling my funds and interpreting its account agreement and federal law.

10. Requested relief I respectfully request that the CFPB : Require PNC to immediately release all Funds along all Accounts that have been closed Investigate PNCs attempt to return cleared federal funds to the Treasury.

Investigate PNCs attempt to use account agreements to bypass Regulation CC. 


Investigate whether the XX/XX/XXXX account closure constitutes retaliation. 


Investigate whether PNC escalated actions based on discriminatory criteria.

Company response to consumer: Closed with explanation