Consumer complaint received 2025-11-05 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem accessing account
Company: PNC Bank N.A.
State: FL

Complaint narrative:
CFPB Complaint Narrative Formal Legal Demand for XXXX XXXX XXXX : PNC Bank, N.A. 
Product : Checking / Deposit Account Virtual Wallet Spend Case Numbers ( Existing ) : CFPB XXXX, XXXX, XXXX XXXX Reference : XXXX Complainant : XXXX XXXX, Power of Attorney Account XXXX XXXX ) : Virtual Wallet Spend Account Ending XXXX Summary of Facts On XX/XX/XXXX, a verified U.S. Treasury refund check in the amount of {>= $1,000,000} payable to XXXX was deposited into a joint PNC Bank account ending XXXX by his Power of Attorney, XXXX XXXX XXXX. 
PNC received and posted the U.S. Treasury refund check on XX/XX/XXXX. XXXX XXXX XXXX XXXX ( XXXX ) confirmed the item as valid and paid, making it legally subject to next-business-day availability under 12 C.F.R. 229.10 ( c ) ( 1 ) ( i ). 
Nevertheless, on XX/XX/XXXX, PNC issued a so-called Notice of Hold on a Next-Day Itema notice that did not meet the content or timing requirements of Regulation CC. The notice failed to specify a lawful reason for delay, did not state the date the funds would be available, and extended the hold far beyond the one-day limit permitted for Treasury checks XXXX 
PNC then continued to detain the verified funds for over a month, keeping them restricted until XX/XX/XXXX. This conduct constitutes : A direct violation of 12 C.F.R. 229.10 ( c ) ( 1 ) ( i ) ( failure to make Treasury funds available next business day ) ; A violation of 12 C.F.R. 229.13 ( g ) ( 2 ) ( failure to issue new written notice when the hold basis changed ) ; and A breach of 12 U.S.C. 4008 ( c ) ( prohibition on disclaiming federal funds-availability obligations by contract ). 
PNCs XX/XX/XXXX Hold Notice was therefore procedurally defective and substantively unlawfulit represented an attempt to delay payment on already-verified federal funds under color of administrative review.

instead of releasing those verified funds, PNC imposed a new account-level hold, froze all balances, and on XX/XX/XXXX transferred the full amount into a suspense account. 
On XX/XX/XXXX, PNC issued a Final Response letter admitting the funds were in suspense status and that the bank was continuing its review. The letter further stated that the account would be closed and that any funds owed will be sent via cashiers checkbut only after new documentation and in-person review by the payee. No such payment has ever been initiated. 
PNC has since attempted to mark this matter resolved, though no lawful disbursement has occurred and the funds remain detained in the suspense ledger. 
1. Power of Attorney and Account Authority on File PNCs own documents confirm the legitimacy of XXXX XXXX fiduciary role : The Power of Attorney authorization has been on file since XX/XX/XXXX ; The signature cards were executed and accepted by PNC on XX/XX/XXXX, listing XXXX XXXX XXXX as Power of Attorney on the account PNCs suggestion that XXXX XXXX XXXX is unverified contradicts its own account registration and internal certifications. The POA remains valid, binding, and legally sufficient under federal and Florida banking law.

2. Violation of Regulation CC and EFAA After verification, PNCs continued restriction of funds violates the Expedited Funds Availability Act and 12 C.F.R. Part 229. The following provisions have been breached : 229.10 ( c ) ( 1 ) ( i ) U.S. Treasury checks must be available for withdrawal no later than the next business day after deposit.

229.13 ( g ) ( 2 ) When the reason for delay changes, the bank must provide a new written notice. None was given when the hold became a suspense transfer.

12 U.S.C. 4008 ( c ) Banks may not contractually limit their statutory obligations.

PNCs conversion of verified funds into a suspense account without new written notice constitutes an unlawful re-hold and constructive detention of federal funds.

3. Contractual Fine-Print Reliance Is Invalid PNCs Final Response cites sections of its Virtual Wallet Fine Printsuch as Collecting Your Deposits, Longer Delays May Apply, and Closing Your Account. These boilerplate terms can not override federal statute. Under 12 U.S.C. 4008 ( c ), any clause purporting to extend holds or delay availability on Treasury checks is null and void.

4. PNC then attempted to close CFPB complaints as resolved, even though the funds were never released.

5. Unlawful and Unwarranted Extra Review Demands XXXX XXXX XXXX XXXX ( XXXX XXXX, XXXX ) goes far beyond any lawful verification process. After acknowledging that the Treasury check was verified and the funds moved to a suspense ledger, PNC demanded the following : Provide documentation connecting the payee to the address on the check ; Provide documentation explaining the reason for receiving the amount of the check ; Provide confirmation of the payees occupation ; and Require the payee XXXX XXXX to appear in person with two forms of identification for verification.

Once this is received, PNC will continue its review and upon completion will close the account and send any funds owed by cashiers check. 
PNC XXXX XXXX, XX/XX/XXXX A. Legally impermissible after verification Once a Treasury item clears, a bank has no statutory authority to impose new review steps. 31 C.F.R. 1020.220 ( FinCEN CIP Rule ) requires identity verification only at account opening. Re-demanding personal appearance months later is unlawful re-verification and harassment under the guise of compliance.

B. Demanding occupation and refund purpose is outside authority Treasury disbursements are governed by federal law. No private bank may interrogate a citizen about the reason for a Treasury refund or their occupation before releasing verified funds. Such behavior constitutes profiling and abuse of discretion, violating 12 C.F.R. 21.21 ( c ) and 12 U.S.C. 5531 ( a ).

C. The suspense account plus new ID request proves bad faith Even if every new demand were satisfied, PNCs own letter admits the funds would still remain in review and the account would still be closed. That exposes these steps as stall tactics to delay payment and evade oversight. A lawful verification process ends once authenticity is confirmed ; PNCs endless review lacks any regulatory basis and violates UCC 1-304 ( duty of good faith ).

D. CFPB Oversight Requested PNCs 
conduct represents a systemic misuse of compliance procedures to detain verified Treasury proceeds. The CFPB should : Investigate PNCs re-verification demands that violate 31 C.F.R. 1020.220, 12 C.F.R. 229.10 ( c ) ( 1 ) ( i ), and 12 U.S.C. 5531 ; Refer the matter to the Office of the Comptroller of the Currency ( OCC ) for enforcement ; and Direct PNC to release the funds immediately and cease all post-verification demands.

E. Summary Statement Requiring a verified payee to return to the branch with two IDs and proof of occupation after a Treasury check cleared is far outside PNCs statutory authority. It conditions release of federal funds on unjustified personal interrogation, behavior that is both legally indefensible and institutionally unethical.

6. Relief Requested Reopen and continue active supervision of all related CFPB cases.

Require PNC to immediately release the verified funds held in the suspense account.

Obtain from PNC all internal records authorizing the XX/XX/XXXX suspense transfer and any supposed review. 


Prevent PNC from closing this case as resolved until full payment is confirmed and all holds are lifted. 


Refer this matter to the XXXX for disciplinary review of PNCs deposit-review policies.

Final Statement This matter remains unresolved. PNCs continued detention of verified Treasury funds, coupled with unlawful re-verification demands and disregard for a valid Power of Attorney, constitutes ongoing violations of federal banking law and consumer-protection statutes. 
The CFPBs immediate oversight is requested to compel PNC Bank to release the funds, end its unlawful review, and ensure accountability for misuse of compliance protocols.

Company response to consumer: Closed with explanation