Consumer complaint received 2025-12-08 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Deposits and withdrawals
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: WA

Complaint narrative:
I am filing a complaint because Bank of America has repeatedly placed improper and unlawful holds on deposited checks in violation of Regulation CC. These holds have included two Washington State Treasurer checks in XX/XX/year> and an earlier XXXX retirement distribution check. In one case, I experienced financial harm requiring a {$20000.00} 401k withdrawal. 

XXXX. XX/XX/year> State of Washington Treasurer Check {$19000.00} ( In-Person Deposit ) I deposited this check at a Bank of America branch . The bank placed a full hold until XX/XX/year>. The written notice stated only : We have information indicating the check ( s ) may be returned. 

This does NOT satisfy Regulation CC 229.13 ( e ), which requires a specific factual reason indicating collectibility concern. The notice uses impermissible boilerplate language ( document attached ) Additionally, Regulation CC 229.10 ( c ) ( 1 ) ( iv ) requires that at least {$5500.00} of a state or local government check deposited in person be available the next business day. The bank instead held the entire amount without justification. 

XXXX. XX/XX/year> State of Washington Treasurer Check {$5300.00} ( ATM Deposit ) The next day, I deposited another State of Washington check for {$5300.00} via ATM. Bank of America is this check until XX/XX/year> as well. 

I received no written notice, which is a violation of 229.13 ( g ) - ( h ). ATM deposits are still subject to the statutory next-day availability requirement for government checks when deposited into the payees own account ( 229.10 ( c ) and 229.19 ( a ) ).

Again, the bank failed to release the required next-day funds and did not provide a valid exception-hold reason. 

XXXX XXXX XXXX XXXX / XXXX XXXX XXXX XXXX Check 27-Day Hold with No Notice I deposited a retirement distribution check ( drawn on XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX on XX/XX/year>. The bank did not release the funds until XX/XX/year> 27 days later. 

Bank of America provided no written notice, despite written notice being mandatory under 229.13 ( g ) - ( h ). I was later told verbally that the hold was due to a minor misspelling of my middle name, which is not a lawful basis for an extended hold and does not constitute reasonable cause under 229.13 ( e ).

This delay forced me to take 401k withdrawal, so it could be wired into my account, causing financial harm. 

4. Pattern of Noncompliance Across all three checks, Bank of America : Held funds longer than permitted under Reg CC Used vague, boilerplate hold explanations Failed to provide legally required written notices Withheld required next-day availability amounts Applied full holds where partial availability is required Caused an overdraft cycle Caused material financial harm I request that the CFPB investigate these violations and require Bank of America to take corrective action.

In all three cases I spent lots of time going round and round on the phone, chat, or in person attempting to escalate, in all three cases their internal policies were referenced indicating these policies override federal statutes.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with monetary relief