Consumer complaint received 2025-10-09 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Deposits and withdrawals
Company: PNC Bank N.A.
State: FL

Complaint narrative:
CFPB Complaint Against PNC BANK PNC Bank withheld Treasury funds after check was Verified and Paid Improper Reg CC Hold & Misrepresentation On XX/XX/year>, I deposited a U.S. Treasury check for {>= $1,000,000} into my PNC Bank account ending in XXXX. The deposit posted on XX/XX/year>, yet no funds were made available, despite federal law requiring next-day availability for U.S. Treasury checks payable to the depositor. 

On XX/XX/year>, PNC issued a Funds-Availability Delay Notice ( Ref # XXXX ) stating We believe a check you deposited may

not be paid and that the bank must verify that the check will be paid. PNC then locked my account and withheld access to the deposited funds. The Treasury Check Verification System ( TCVS ) shows the item status as Verified and Paid, confirming that the U.S. Treasury and Federal Reserve have fully settled payment to PNC Bank. Once a check is Verified and Paid, settlement is final under 31 C.F.R. 240.4 ( b ). PNC has provided no specific factual basis to justify a reasonable-cause-to-doubt-collectibility hold as required by Reg CC 229.13 ( e ), nor a written notice with a factual explanation and release date as required by 229.13 ( g ). PNCs statement that it is waiting on Treasury is false once a Verified and Paid designation has been issued. I allege violations of Regulation CC and UDAAP ( 12 U.S.C. 5531 ). I request that the CFPB require PNC Bank to release the funds immediately, confirm that no reversal will occur, and remediate any fees or losses caused by the unlawful hold.

My assigned PNC representative, XXXX XXXX ( XXXX ), identified as a Customer Liaison / Case Manager ( phone XXXX ), has repeatedly upheld the banks improper position during multiple calls. 

On XX/XX/year>, XXXX stated that PNC reserves the right to place a hold on any deposit over {$50000.00}, even for a U.S. Treasury check, claiming this was consistent with PNCs policy and procedures which she asserted follow the law. However, this statement is incorrect : under 12 C.F.R. 229.13 ( b ) ( 1 ), Treasury checks are expressly exempt from the large-deposit exception. 

On XX/XX/year>, XXXX further claimed that PNC was reaching out to the Treasury to see if the check will pay, despite the TCVS already confirming that the item was Verified and Paid. She also stated that she could not give a time limit for fund release and presented only two options : 1. Wait indefinitely for a response from Treasury, or 2. Ask Treasury to reclaim and reissue the check. 

During a follow-up conversation on XX/XX/year>, XXXX admitted

that PNC already has the funds and that the check has been paid, while continuing to assert that PNC was waiting on Treasury for further instruction. This direct contradiction confirms that the funds are being knowingly held after payment was received, which renders the continuing hold misleading and in violation of Regulation CCs availability requirements. These statements misrepresent both Regulation CC and Treasury settlement procedures. Once TCVS shows Verified and Paid, payment is final, and no further action from the Treasury exists. The
funds legally belonged to my principal, XXXX XXXX, and should have been available on XX/XX/year>, under Regulation CC 229.10 ( c ) ( 1 ) ( i ).

PNCs continued hold and misrepresentations constitute : An illegal hold and improper Regulation CC violations under 12 C.F.R. Part 229, and Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) under 12 U.S.C. 5531, by misleading the customer and withholding verified federal funds.

Call Record and Concern On XX/XX/year> ( XXXX XXXX  XXXX XXXX ET ), I spoke with PNC Deposit Fraud Department representative XXXX XXXX. 
The documented call transcripts shows she stated that : PNC has the funds but will not release them until the Treasury contacts PNC. The only two options were for the Treasury to contact PNC or for me to request a recall of the check. She also claimed that The Treasury has the right to request the funds back at any time. This pattern of statements indicates PNC may be deliberately
steering the outcome toward a Treasury-initiated recall or delay, rather than following the mandatory next-day availability rule for Treasury checks under Regulation CC 229.10 ( c ) ( 1 ) ( i ).

Such behavior could allow the bank to temporarily benefit from holding fully paid federal funds a potential violation of the Expedited Funds Availability Act ( 12 U.S.C. 4001 et seq. ) and the CFPBs UDAAP prohibition ( 12 U.S.C. 5531 ).

At present, PNC admits it has both the check and the funds, but refuses to release them, claiming to be waiting for Treasury confirmation.

No written reclamation notice or recall has been issued by the U.S. Treasury, and PNC has produced no documentation establishing reasonable cause to doubt collectibility.

Requested Action 1. Direct PNC Bank to release the verified Treasury funds immediately.

2. Require PNC to produce copies of all communications with the U.S. Treasury or Federal Reserve relating to this check.

3. Investigate PNC for potential Regulation CC and UDAAP violations arising from the misrepresentation of Treasury recall procedures and the unreasonable delay of funds availability.

4. Ensure full compliance with 12 C.F.R. Part 229 and the Expedited Funds Availability Act ( 12 U.S.C. 4001 et seq. ) going forward. 


Respectfully XXXX XXXX Attorney in fact And POA For XXXX XXXX The following exhibits are submitted as supporting evidence to substantiate the facts and regulatory violations detailed in this complaint : Exhibit A Lawful Deposit Authorization Exhibit B Proof of Treasury Check Deposit Posted Exhibit C Verified Deposit Posting Confirmation ( XX/XX/year> ) Exhibit D Proof PNC Bank Received Payment from U.S. Treasury per TCVS Exhibit E PNC Funds-Availability Delay Notice ( Issued in Violation of Regulation CC ) Exhibit F Written Notice to PNC Fraud Department Confirming Verified Treasury Payment Exhibit H Related CFPB Complaint Filed Against PNC Bank ( Supporting Evidence of Pattern and Practice ) And duly Authorized Power Of Attorney Documents showing my Legal Authority as XXXX XXXX Agent And POA

Company response to consumer: Closed with explanation