Back Hub 18: Payment Platforms

California Stripe Account Freeze Demand Letter

Recover frozen funds from Stripe account holds, terminations, and reserve disputes. California law provides merchant protections against wrongful fund holds by payment processors.

90-120 Days
Typical Stripe Hold Period
$1M+
Funds Recovered for Clients
14 Days
Demand Letter Deadline
Stripe Account Freezes in California

Stripe is the dominant payment processor for online businesses, handling billions in transactions annually. When Stripe freezes your account or withholds your funds, it can cripple your business overnight. California merchants have legal options to challenge wrongful freezes and recover their money.

Critical: Stripe can freeze your account with little or no warning, holding funds for 90-120 days or longer. Unlike bank accounts, payment processor funds have fewer regulatory protections. A well-crafted demand letter citing California law can accelerate fund release.
Common Stripe Freeze Triggers
Trigger Description Recovery Outlook
High Chargeback Rate Chargeback ratio exceeds 1% of transactions; Stripe flags account for elevated dispute risk Moderate - Must demonstrate chargeback mitigation and dispute validity
Sudden Volume Spike Processing volume increases dramatically without prior notice to Stripe Good - Provide documentation of legitimate business growth
Prohibited Business Type Business allegedly violates Stripe's Restricted Businesses list (CBD, supplements, adult content, etc.) Challenging - May need alternative processor; focus on fund release
Fraud Flags Stripe Radar detects suspicious transaction patterns or customer complaints Variable - Depends on evidence of legitimate transactions
Reserve/Balance Issues Rolling reserve triggered or negative balance from refunds exceeds available funds Good - Clear accounting dispute with specific dollar amounts
Documentation Requests Failure to respond to Stripe's identity verification or business documentation requests Excellent - Provide requested documentation immediately

Why Stripe Freezes Are Devastating

  • Cash flow destruction: 90-120 day holds can bankrupt small businesses
  • No warning: Freezes often happen without advance notice
  • Vague explanations: Stripe cites "elevated risk" without specifics
  • Arbitration clause: Terms of Service require AAA arbitration
  • Limited appeal process: Internal review often rubber-stamps initial decision

Your Immediate Action Steps

  • Document everything: Screenshot dashboard, emails, transaction history
  • Respond to requests: Provide any documentation Stripe requested immediately
  • Calculate exact amount: Determine precisely how much is frozen
  • Review Terms of Service: Identify specific provisions Stripe allegedly violated
  • Preserve communications: Save all emails and support chat logs
California Advantage: California's strong consumer and business protection laws, including the UCL and Money Transmission Act, provide leverage against payment processors that other states lack. A California-based demand letter carries more weight than a generic complaint.
California Legal Framework for Stripe Disputes

California provides robust legal protections for businesses dealing with payment processor misconduct. Multiple state laws apply to Stripe's conduct, and California courts have shown willingness to hold payment processors accountable.

California Money Transmission Act

Financial Code Division 1.2, Chapter 3

Stripe operates as a licensed money transmitter in California under DFPI oversight. Money transmitters must handle customer funds in accordance with their license terms and cannot unreasonably withhold funds. The DFPI can investigate complaints and take enforcement action against processors that violate their obligations.

Unfair Competition Law (UCL)

Business & Professions Code Section 17200

California's UCL prohibits any "unlawful, unfair, or fraudulent business act or practice." Stripe's pattern of freezing accounts without adequate notice, holding funds beyond reasonable periods, or failing to provide itemized accountings may constitute unfair business practices. UCL provides for restitution and injunctive relief.

Implied Covenant of Good Faith and Fair Dealing

California Contract Law

Every California contract includes an implied covenant that neither party will do anything to unfairly interfere with the other's right to receive the benefits of the agreement. Stripe's arbitrary account freezes or excessive fund holds may breach this implied covenant, even if technically permitted by the Terms of Service.

California Commercial Code

Commercial Code Section 11101 et seq.

Governs payment systems and fund transfers in California. Provides framework for merchant rights in electronic payment disputes and establishes duties for payment intermediaries.

California Statutes of Limitations
Claim Type Deadline Code Section
UCL Claim 4 years B&P Code Section 17208
Written Contract Breach 4 years CCP Section 337
Breach of Implied Covenant 4 years CCP Section 337
Conversion (Wrongful Withholding) 3 years CCP Section 338(c)
Fraud 3 years from discovery CCP Section 338(d)
Arbitration Clause: Stripe's Terms of Service require binding arbitration through AAA. However, California law limits enforcement of unconscionable arbitration clauses, and small claims court remains available for disputes under $12,500 (individuals) or $6,250 (businesses). A demand letter often resolves disputes before arbitration becomes necessary.
California DFPI Complaints

The California Department of Financial Protection and Innovation (DFPI) regulates money transmitters including Stripe. Filing a DFPI complaint:

  • Creates official regulatory record of your dispute
  • May trigger DFPI inquiry to Stripe
  • Supports pattern evidence for enforcement actions
  • File online at dfpi.ca.gov/file-a-complaint
  • Reference Stripe's California money transmitter license
Leverage Point: Stripe's continued operation in California depends on its DFPI license. A pattern of complaints or regulatory scrutiny creates significant business risk for Stripe. Mentioning DFPI complaint filing in your demand letter often accelerates resolution.
Stripe Terms of Service and Policies

Understanding Stripe's contractual framework is essential for crafting an effective demand letter. Stripe's Terms of Service and Connected Account Agreement govern your relationship, but California law limits Stripe's ability to enforce unconscionable provisions.

Key Stripe Agreement Provisions

Stripe Services Agreement

The master agreement governing all Stripe accounts. Key provisions affecting account freezes:

  • Section 3 (Your Stripe Account): Stripe can suspend or terminate accounts for violations, but must provide notice
  • Section 7 (Reserves): Stripe can establish rolling reserves or withhold funds for anticipated chargebacks
  • Section 8 (Security Interest): Stripe claims security interest in your receivables
  • Section 15 (Termination): Either party can terminate with notice, but fund release timeline is disputed

Connected Account Agreement

Additional terms for platform-connected accounts (Stripe Connect). If you process through a platform using Stripe:

  • Platform may have additional restrictions beyond Stripe's standard terms
  • Dispute may involve both Stripe and the platform
  • Fund flow and hold policies may differ from direct Stripe accounts
Stripe's Restricted Businesses List

Stripe prohibits or restricts numerous business categories. If your freeze relates to business type, review the current list:

Category Examples Notes
Financial Services Cryptocurrency, forex, securities without license Some allowed with additional verification
Regulated Products CBD, tobacco, firearms, pharmaceuticals State-by-state legality affects Stripe policy
Adult Content Pornography, adult services, dating with adult features Generally prohibited on standard Stripe
High-Risk Services Tech support, travel agencies, ticket resellers May require additional documentation
Subscription/Recurring High-ticket subscriptions, negative option billing Higher chargeback risk triggers scrutiny
Reserve Requirements

Stripe may impose reserves on your account in several ways:

Rolling Reserve

Stripe withholds a percentage (typically 5-10%) of each transaction for a set period (usually 90 days). This creates a cash buffer against chargebacks.

Dispute angle: Challenge percentage as excessive or release timeline as unreasonable.

Minimum Reserve

Stripe requires you maintain a minimum balance (e.g., $10,000) in your account at all times. Funds below this threshold are not available for payout.

Dispute angle: Challenge amount as disproportionate to actual risk.

Key Leverage Point: Stripe's Terms of Service grant broad discretion, but California's implied covenant of good faith requires Stripe to exercise that discretion reasonably. Arbitrary or pretextual freezes violate this duty even if technically permitted by the contract language.
Stripe's Internal Appeal Process

Before sending a demand letter, exhaust Stripe's internal process:

  1. Dashboard Appeal: Use the Stripe Dashboard to submit an appeal with documentation
  2. Support Ticket: Open a support ticket specifically addressing the freeze
  3. Account Manager: If you have a dedicated account manager, escalate directly
  4. Email Legal: Contact legal@stripe.com for complex disputes
  5. Document Denials: Save all responses - these support your demand letter
Evidence and Documentation Checklist

Strong documentation is essential for recovering frozen Stripe funds. Gather evidence immediately - the more comprehensive your records, the stronger your demand letter.

Account Documentation

  • Stripe Dashboard screenshots showing frozen balance
  • Complete transaction history export (CSV)
  • Payout history showing last successful payout
  • Account settings and verification status
  • Any reserve requirements displayed in dashboard

Communications

  • All emails from Stripe (freeze notice, requests, denials)
  • Support chat transcripts
  • Phone call notes with dates and representative names
  • Appeal submissions and responses
  • Any documentation you provided to Stripe

Business Legitimacy Proof

  • Business formation documents (LLC, Corp filings)
  • California business license
  • EIN documentation
  • Website/product documentation
  • Customer testimonials or reviews
  • Fulfillment records (shipping confirmations, delivery proof)

Chargeback/Dispute Records

  • Complete chargeback history with outcomes
  • Evidence submitted for each dispute
  • Win/loss ratio on disputes
  • Refund policy and customer service records
  • Fraud prevention measures in place
Calculating Your Damages

Your demand letter should include specific damage calculations:

Damage Category Calculation Method Documentation Needed
Frozen Balance Exact amount shown in Stripe Dashboard Dashboard screenshot with date
Lost Business Revenue lost while unable to process payments Sales history, canceled orders, lost customers
Interest on Funds California legal rate (10%) on frozen amount Duration of hold, amount held
Alternative Processing Costs Higher fees paid to backup processor Invoices from alternative processor
Business Expenses Costs incurred due to cash flow disruption Late fees, emergency financing costs
Preservation Demand: Include a document preservation demand in your letter. Stripe must retain all records related to your account, the freeze decision, internal communications, and any risk assessments. Spoliation of evidence can result in adverse inferences.
Evidence for Specific Freeze Types

For Chargeback-Related Freezes

  • Complete chargeback history showing actual rate vs. claimed rate
  • Evidence that chargebacks were fraudulent or resolved in your favor
  • Customer communications supporting legitimate transactions
  • Delivery confirmations for physical goods
  • Access logs/usage records for digital products

For Business Type Disputes

  • Detailed business description and product catalog
  • Evidence business type was disclosed to Stripe at signup
  • Any licenses or permits for regulated products
  • Legal opinions on product legality (if applicable)
  • Comparison to similar businesses Stripe processes
Sample California Stripe Account Freeze Demand Letter

Customize this template for your specific situation. Include all relevant facts, specific dollar amounts, and supporting documentation.

[Your Name / Business Name] [Your Address] [City, CA ZIP] [Your Email] [Date] Stripe, Inc. Attn: Legal Department 354 Oyster Point Boulevard South San Francisco, CA 94080 Via Email: legal@stripe.com Via Certified Mail, Return Receipt Requested Re: Demand for Release of Frozen Funds and Account Reinstatement Account ID: [acct_XXXXXXXXXX] Frozen Amount: $[Amount] Freeze Date: [Date] Dear Stripe Legal Department: I represent [myself/my company, Business Name], a California [sole proprietorship/LLC/corporation] operating in [City], California. I am writing to demand immediate release of $[Amount] frozen in my Stripe account since [Date], and to address the wrongful termination/suspension of my merchant account. ACCOUNT HISTORY AND BUSINESS OPERATIONS I have operated a Stripe account since [Year], processing approximately $[Monthly Volume] monthly in legitimate [describe business - e.g., "e-commerce sales of consumer electronics"]. Prior to the freeze, my account was in good standing with a chargeback rate of [X.XX]%, well below industry standards and Stripe's 1% threshold. My business is properly licensed in California, operates in full compliance with applicable law, and has never engaged in prohibited activities under Stripe's Terms of Service. FACTS REGARDING THE FREEZE On [Date], I received notification that Stripe had [frozen my account/placed funds on hold/terminated my account] citing [quote Stripe's stated reason, e.g., "elevated risk" or "violation of Terms of Service"]. [Describe specific circumstances:] - The freeze occurred [with/without] prior warning - Stripe has provided [no specific/limited/the following] explanation: [details] - I have submitted [describe documentation provided] in response to Stripe's requests - Stripe has [approved/denied/not responded to] my appeal dated [Date] As of this letter, Stripe holds $[Amount] of my funds and has indicated a [90/120/180]-day hold period, which is commercially unreasonable and legally unjustified. LEGAL ANALYSIS Stripe's conduct violates California law and breaches its contractual obligations: 1. Breach of Contract and Implied Covenant of Good Faith While Stripe's Terms of Service grant discretion regarding account management, California law implies a covenant of good faith and fair dealing in every contract. Carma Developers, Inc. v. Marathon Development California, Inc., 2 Cal.4th 342 (1992). This covenant prevents Stripe from exercising contractual discretion in bad faith or in a manner that frustrates my reasonable expectations under the agreement. I disclosed my business type accurately at account creation. I have maintained a low chargeback rate. I have complied with all documentation requests. Stripe's decision to freeze my account and hold my funds for [90-120+ days] is arbitrary, pretextual, and designed to deprive me of the benefit of our agreement. 2. California Unfair Competition Law (B&P Code Section 17200) Stripe's pattern of freezing merchant accounts without adequate notice, holding funds for excessive periods, and providing vague or pretextual explanations constitutes an unfair business practice under California's UCL. These practices cause substantial injury to California merchants, are not outweighed by countervailing benefits, and could reasonably be avoided by Stripe through better notice and faster resolution procedures. 3. California Money Transmission Act Stripe operates in California as a licensed money transmitter under the oversight of the Department of Financial Protection and Innovation (DFPI). Stripe's license obligates it to handle customer funds responsibly and in accordance with its stated policies. Unreasonable fund holds and arbitrary account terminations may constitute grounds for DFPI enforcement action. 4. Conversion Stripe's continued withholding of my funds without legitimate justification constitutes conversion under California law. I have demanded return of these funds; Stripe has refused. I am entitled to the immediate return of my property plus interest. DEMAND I demand that Stripe: 1. Immediately release the full frozen balance of $[Amount] to my designated bank account; 2. Provide a complete, itemized accounting of all funds received, held, and disbursed from my account; 3. Provide specific, documented reasons for the account freeze, including any chargeback data, fraud flags, or Terms of Service violations allegedly supporting this action; 4. Reinstate my account in good standing, or alternatively, confirm in writing that my account is closed with no further obligations; 5. Confirm that no negative reports have been filed with MATCH or any similar merchant blacklist database, and remove any such reports if filed; 6. Compensate me for consequential damages including [lost business revenue, emergency financing costs, alternative processor fees] totaling approximately $[Amount]. DEADLINE AND CONSEQUENCES I require a substantive response to this demand within fourteen (14) calendar days of the date of this letter. If Stripe fails to release my funds and adequately respond within this period, I will pursue all available remedies, including: - Filing a formal complaint with the California Department of Financial Protection and Innovation (DFPI) - Initiating arbitration pursuant to Stripe's Terms of Service, seeking the frozen balance, consequential damages, and attorney fees - Filing in California Small Claims Court for claims within jurisdictional limits - Pursuing a putative class action if investigation reveals a pattern of similar conduct affecting California merchants - Reporting Stripe's conduct to the California Attorney General's Office DOCUMENT PRESERVATION This letter constitutes formal notice to preserve all documents, communications, and data related to my account, including but not limited to: internal risk assessments, chargeback data, fraud flags, communications between Stripe employees regarding my account, and any policies or procedures applied to my account freeze decision. I am available to discuss resolution at [Your Phone] or [Your Email]. I remain willing to resolve this matter without formal proceedings if Stripe acts in good faith to release my funds promptly. Sincerely, [Your Signature] [Your Printed Name] [Title, if applicable] Enclosures: - Stripe Dashboard screenshots showing frozen balance - Complete email correspondence with Stripe - Business license and formation documents - Transaction history and chargeback records - Documentation provided to Stripe during appeal - Damage calculations and supporting invoices
Important: Send your demand via certified mail with return receipt AND email to legal@stripe.com. Keep copies of everything. Customize the letter with your specific facts - generic letters are less effective. Consider having an attorney review before sending for claims over $10,000.
After Sending the Demand Letter
  1. Track delivery: Monitor USPS tracking and save delivery confirmation
  2. Log responses: Document all communications after sending
  3. Prepare for arbitration: If no response, research AAA filing procedures
  4. File DFPI complaint: Submit complaint after deadline passes if unresolved
  5. Consult attorney: For amounts over $10,000, consider legal representation
How I Handle California Stripe Freeze Cases

I personally draft and negotiate Stripe account freeze demand letters for California merchants. These cases require understanding payment processor practices, California commercial law, and effective escalation strategies.

Case Evaluation

  • Review freeze circumstances and Stripe's stated reasons
  • Analyze your chargeback history and account standing
  • Assess strength of claims under California law
  • Calculate total damages including consequential losses
  • Identify leverage points specific to your situation

Demand Letter Drafting

  • Comprehensive demand citing California UCL and contract law
  • Specific damage calculations with supporting documentation
  • Document preservation demands
  • Strategic deadline and escalation framework
  • DFPI complaint preparation if needed

Escalation Support

  • DFPI complaint drafting and submission
  • AAA arbitration demand preparation
  • Negotiation with Stripe legal team
  • Small claims court representation (within limits)
  • Coordination with litigation counsel for large claims

Typical Outcomes

  • Accelerated fund release (often within 2-4 weeks)
  • Reduced reserve requirements
  • Account reinstatement in appropriate cases
  • MATCH removal or prevention
  • Documented resolution for business continuity

Stripe Froze Your California Business Account?

I handle California Stripe freeze demand letters and payment processor disputes personally. Contact me for a case evaluation.

Email: owner@terms.law
Fee Structure

Stripe freeze cases are typically handled on:

  • Flat fee: $450 for demand letter preparation, submission, and initial response handling
  • Hourly: $240/hour for complex cases, arbitration preparation, or extended negotiation
  • Contingency: 33% of recovered funds for cases requiring arbitration or litigation
Free Initial Review: I review Stripe freeze cases at no charge to assess whether a demand letter is likely to succeed. Send your Stripe communications and dashboard screenshots to owner@terms.law with "Stripe Freeze" in the subject line.
What Makes a Strong Stripe Freeze Case

Strong Cases

  • Low chargeback rate (under 1%)
  • Business type properly disclosed at signup
  • Complete documentation provided to Stripe
  • Freeze occurred without warning or explanation
  • Legitimate business with verifiable customers
  • Funds held beyond 120 days

Challenging Cases

  • High chargeback rate (over 1%)
  • Business type changed without notifying Stripe
  • Products genuinely violate Stripe's restricted list
  • Significant fraud indicators on account
  • Failed to respond to Stripe's documentation requests
  • Prior account terminations at other processors