Sample Demand Letters
Sample 1: Chime Account Freeze Demand
[Your Name]
[Address]
[Email]
[Phone]
[Date]
Chime Financial, Inc.
101 California Street, Suite 2300
San Francisco, CA 94111
Via Email: support@chime.com; legal@chime.com
Via Certified Mail
Re: Unlawful Account Freeze - Account [Member Number/Email]
Dear Chime:
I am writing regarding Chime's freeze of my account and withholding of $[Amount] in funds.
BACKGROUND:
On [Date], I received notice that my Chime account was "under review" and all access was frozen. I have been unable to access my funds for [number] days. My account balance is $[Amount], which represents [explain: my entire paycheck / rent money / disability benefits / etc.].
FREEZE IS UNJUSTIFIED:
Chime has provided no legitimate explanation for this freeze. [Select applicable:]
1. LEGITIMATE DEPOSIT:
[If tax refund:] The deposit of $[Amount] on [Date] was my federal/state tax refund from the IRS. I have filed taxes for [X] years using the same bank routing for direct deposit. This is a routine, legal transaction. [Attach: IRS transcript or tax return]
[If paycheck:] The deposit was my biweekly paycheck from my employer [Company Name] where I have worked for [X years/months]. [Attach: pay stub, employer verification letter]
[If settlement/legal payment:] The deposit was a settlement payment from [case/source]. [Attach: settlement agreement, court order, attorney letter]
2. IDENTITY VERIFIED:
I have submitted all requested verification: driver's license (front and back), selfie with ID, utility bill showing my address, and Social Security number. Chime verified my identity when I opened the account [date] and has had no issues for [duration].
3. NO FRAUD:
All transactions on my account are legitimate and authorized by me. I have receipts and can verify any transaction Chime questions.
CHIME'S BREACH:
Chime's Deposit Account Agreement states that funds "will be made available for withdrawal" per standard timelines. By freezing my account indefinitely without explanation, Chime has:
• Breached contract (Deposit Account Agreement)
• Breached implied covenant of good faith and fair dealing
• Converted my funds (wrongful withholding)
• Violated Regulation E (Electronic Fund Transfer Act) - unreasonable delay in making funds available
I submitted documents Chime requested on [date], yet have received only automated responses saying "we're reviewing your account." This is unacceptable.
FINANCIAL HARDSHIP:
This freeze has caused severe hardship:
• Unable to pay rent due [date] - facing eviction
• Cannot buy groceries or gas
• Medical bills unpaid
• [Other specific hardships]
This is my primary bank account. Chime has frozen my entire livelihood with no reasonable explanation or timeline for resolution.
DEMAND:
I demand Chime immediately:
1. Unfreeze my account and restore full access
2. Release all funds ($[Amount]) within 3 business days
3. Provide written explanation for freeze with specific evidence (not vague "security review")
If Chime determines account must be closed, release funds immediately via ACH to [external account] rather than waiting weeks for check.
LEGAL ACTION:
If Chime does not release funds within 7 days, I will:
• File arbitration demand under Deposit Account Agreement Section [X]
• File lawsuit in small claims court for conversion (wrongful withholding of funds)
• Seek damages: $[Amount] withheld + consequential damages (late fees, overdraft fees at other accounts, missed rent penalty) + emotional distress
• File complaints with:
- Consumer Financial Protection Bureau (CFPB)
- Federal Deposit Insurance Corporation (FDIC)
- California Department of Financial Protection and Innovation
- Office of the Comptroller of the Currency (regulates Bancorp Bank/Stride Bank)
• Join existing class action litigation against Chime (if applicable)
I estimate total damages at $[withheld amount + 3-6 months expenses + penalties] if this matter is not resolved immediately.
REGULATORY ATTENTION:
I have already filed CFPB Complaint #[if filed]. Chime's pattern of freezing customer accounts for legitimate deposits (tax refunds, paychecks) has attracted regulatory scrutiny and multiple class action lawsuits. I urge Chime to resolve this matter before adding to that litigation burden.
Please respond within 7 days with concrete resolution.
Sincerely,
[Your Name]
Enclosures:
• Account statements/screenshots showing balance
• Freeze notice screenshot
• Source of funds documentation [tax return, pay stub, settlement docs]
• Identity verification documents already submitted
• Support ticket history
Sample 2: Cash App Business Use Freeze - Attorney Demand
[Law Firm Name]
[Address]
[Phone / Email]
[Date]
Block, Inc. (f/k/a Square, Inc.)
c/o Cash App Legal
1955 Broadway, Suite 600
Oakland, CA 94612
Via Email: legal@cash.app
Via Certified Mail
Re: Cash App Account Freeze - [Client Name], Account [$Cashtag]
Dear Cash App / Block:
I represent [Client Name] regarding Cash App's freeze of their account and withholding of $[Amount].
FREEZE BACKGROUND:
On [Date], Cash App froze my client's account citing "violation of Terms of Service - business use on personal account." Cash App is holding $[Amount], which represents [explain: client's freelance income, small business receipts, etc.].
CLIENT'S POSITION:
1. LEGITIMATE ACTIVITY:
My client used Cash App to receive payments for [describe: freelance services, selling used items, etc.]. While Cash App's TOS states personal accounts are for personal use only, the line between "personal" and "business" is unclear for:
• Freelancers receiving occasional project payments
• Individuals selling used personal items
• People receiving reimbursements from friends/family for shared expenses
My client's activity does not constitute the type of commercial business use Cash App seeks to prohibit (high-volume merchant activity requiring business account).
2. GOOD FAITH USE:
Client was unaware that their activity violated TOS. Cash App processed these transactions without warning for [X months], giving no indication of policy violation. Had Cash App notified client of issue earlier, client would have ceased activity or opened proper business account.
3. NO FRAUD OR HARM:
All transactions were legitimate. No customer disputes, chargebacks, or fraud. Payers received goods/services as expected. Cash App suffered no harm from this account activity.
LEGAL CLAIMS:
Even if TOS technically violated, Cash App's response is legally problematic:
• Conversion: Withholding $[Amount] in legitimately earned funds
• Breach of implied covenant: Accepting and processing transactions for months, then freezing account without warning
• Unjust enrichment: Cash App collected fees on transactions, then retained customer funds
• Unconscionable contract enforcement: TOS violation does not justify permanent fund seizure
CASH APP'S OPTIONS:
Cash App has right to close account for TOS violation. However, Cash App does NOT have right to permanently withhold client's funds.
Reasonable resolution:
• Close account (client accepts this)
• Release all funds within 7-10 days
• Client commits not to create new personal account
DEMAND:
Release all withheld funds ($[Amount]) to client's linked bank account [or debit card] within 7 business days.
Client waives any claim to account reinstatement and agrees not to open new Cash App personal account. Client simply wants their money returned.
DEADLINE:
Please respond within 7 days. If funds not released, client will:
• File arbitration demand under Cash App Terms of Service
• Pursue conversion claim and breach of implied covenant claim
• Seek damages: $[Amount] withheld + interest + attorney fees + consequential damages (inability to pay bills, late fees, etc.)
• File regulatory complaints (CFPB, California DFPI, FTC)
Client is willing to resolve this amicably with immediate fund release. Litigation benefits neither party.
Please contact me to arrange fund transfer.
Sincerely,
[Attorney Name]
[Law Firm]
CC: Client
Sample 3: Varo AML Freeze - Expedited Release Request
[Your Name]
[Address]
[Email]
[Date]
Varo Bank, N.A.
P.O. Box 12510
Wilmington, DE 19850
Via Email: help@varomoney.com; legal@varobank.com
Re: AML Freeze Resolution - Account [Account Number]
Dear Varo:
I am writing regarding Varo's freeze of my account for alleged AML concerns. I have provided all requested documentation and request expedited fund release.
BACKGROUND:
On [Date], Varo froze my account and requested source of funds documentation for deposits totaling $[Amount]. I have provided:
• Pay stubs from employer [Company Name] (attached)
• Employment verification letter (attached)
• Tax returns showing reported income (attached)
• Bank statements from [other bank] showing transfer history (attached)
• Government-issued ID and Social Security card (previously submitted)
All deposits are from legitimate, legal sources: [employment income / business receipts / family transfers / settlement payment / etc.].
VARO'S ONGOING FREEZE UNJUSTIFIED:
I submitted all requested documents on [Date] - [number] days ago. Varo has provided no update or indication of timeline for review. Meanwhile, I have $[Amount] frozen and inaccessible.
This prolonged freeze after providing complete documentation violates:
• Bank Secrecy Act (allows reasonable investigation, not indefinite freeze)
• Varo's own Deposit Agreement (funds must be made available absent specific legal requirement to withhold)
• Implied covenant of good faith (freeze continues despite my full cooperation)
SETTLEMENT REQUEST:
To resolve this matter:
1. Complete AML review within 5 business days
2. If review finds no issue (as it should - all sources are legitimate), restore account access
3. If Varo chooses to close account, release all funds via ACH to [external account] within 7 days (not 60+ day wait for check)
I have no interest in continuing banking relationship with Varo if Varo does not want my business. I simply want my legitimately earned funds returned promptly.
ALTERNATIVE: LEGAL ACTION
If Varo does not respond within 7 days with concrete resolution timeline, I will:
• File arbitration demand for conversion (wrongful withholding of funds)
• File CFPB complaint against Varo Bank
• File complaint with Office of the Comptroller of the Currency (Varo's primary regulator)
• Sue in small claims court if amount is within jurisdiction (conversion claim)
• Seek damages: $[Amount] + interest + consequential damages + attorney fees if arbitration
I prefer to avoid legal action. Please review my documentation and release funds promptly.
Sincerely,
[Your Name]
[Phone]
Enclosures:
• Pay stubs
• Employment verification letter
• Tax returns
• Bank statements
• Copy of ID (previously submitted)