Consumer complaint received 2025-02-05 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Cashing a check
Company: CITIBANK, N.A.
State: IL

Complaint narrative:
I am submitting this formal complaint against Citibank for imposing an unjustified and unlawful hold on a payroll check I deposited via mobile deposit on XX/XX/XXXX, in the amount of {$1800.00}. Citibanks actions violate my rights as a consumer under the Expedited Funds Availability Act ( Regulation CC, XXXX C.F.R. Part XXXX ) and contradict the terms of its own XXXX XXXX Account XXXX regarding funds availability. 

Summary of Events and Violations My payroll check was accepted for processing the same day ( XX/XX/XXXX ). 
On XX/XX/XXXX, I was notified that the check was placed on hold until XX/XX/XXXX, due to confidential information indicating the check may not be paid. 
This justification lacks transparency and does not meet the regulatory threshold for an exception hold under 12 C.F.R. 229.13. 
I made multiple attempts to resolve the issue with Citibank customer service and a branch manager, receiving conflicting explanations that do not align with Regulation CC or Citibanks stated deposit policies.

o Justification provided by customer service and the local branch manager included a ) that the check was mobile deposit and therefore subjected to longer holding periods and b ) that the account was new. 
Citibank failed to provide a written notice that included a legally valid reason for the hold, in violation of 12 C.F.R. 229.13 ( g ).

Consumer Rights and Citibanks Violations 1. Failure to Make Funds Available Within the Required Timeframe o Under 12 C.F.R. 229.10, payroll checks should generally be available no later than the first business day after deposit. 
o The funds should have been available by XX/XX/XXXX, or at most, by XX/XX/XXXX, if a standard two-business-day hold applied. 
o Citibanks Consumer Deposit Account Agreement states they may also delay the full amount of your check deposits for a longer period ( up to 7 business days ) if exceptional criteria are met, but has failed in their burden of so establishing as indicated in Section 2 of this complaint. Further, their seven day hold is in violation of 12 C.F.R. 229.13 ( h ) which defines a reasonable period for local checks as five business days.

2. Failure to Provide a Valid Exception Hold Justification o Per 12 C.F.R. 229.13, extended holds are only permitted under specific conditions ( e.g., large deposits over {$5500.00}, redeposited checks, repeated overdrafts, or reasonable doubt of collectability ). 
o None of these exceptions apply to my deposit. The check was issued by a reputable employer, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, and drawn from a well-established local financial institution, XXXX XXXX XXXX XXXX 
o The vague claim of confidential information does not constitute reasonable cause to doubt collectability under 12 C.F.R. 229.13 ( e ).

3. Failure to Provide Proper Notice of Hold o Under 12 C.F.R. 229.13 ( g ), Citibank was required to provide a written notice specifying a valid reason for the hold and the exact date the funds would be available.

o The notice I received failed to meet these requirements and contained inconsistent reasoning.

4. Failure to Adhere to Its Own Deposit Agreement o Citibanks Consumer Deposit Account Agreement states that funds from check deposits should generally be available within two business days unless a valid exception applies.

o Citibanks Consumer Deposit Account Agreement includes no clear indication that mobile deposits are subject to longer hold periods solely because they are mobile deposited. 
o My checking account has been open since XX/XX/XXXX, meaning it is not subject to new account hold rules ( 12 C.F.R. 229.13 ( a ) ), which only apply within the first 30 days.

o Despite the check being marked as posted in my account, Citibank is withholding access to the funds without justification.

Requested Action Given these clear violations of federal regulations and Citibanks own policies, I formally request : 1. The immediate release of the {$1800.00} being unlawfully withheld. 
2. A written explanation from Citibank citing specific regulatory provisions that justify this extended hold.

3. An assurance of compliance from Citibank, ensuring it will adhere to Regulation CC and its own funds availability policies in the future.

Since my attempts in promptly resolving this issue directly with Citibank have proven unsuccessful, I am requesting the Consumer Financial Protection Bureau ( CFPB ) investigate this violation and take appropriate regulatory action. I am also prepared to escalate this complaint to the Office of the Comptroller of the Currency ( OCC ) if necessary. 
I appreciate your attention to this matter and look forward to your assistance in ensuring consumer banking rights are upheld.

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 non-monetary relief