Provision record
PayPal · PayPal User Agreement · View original document ↗

Fund Hold on Account Limitation or Termination (Up to 180 Days)

High severity High confidence Explicit document language Common · 277 of 352 platforms
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Document Record

What it is

The agreement authorizes PayPal to hold funds in a limited or terminated account for up to 180 days to cover potential chargebacks, disputes, claims, fees, fines, and penalties.

This analysis describes what PayPal's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision creates a significant liquidity risk for business users who rely on PayPal balances for operational cash flow, as the agreement reserves the right to withhold funds for up to 180 days following an account limitation or termination triggered by PayPal's assessment of risk or policy violation.

Clause Stability Stable

0
Changes
6
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 1874 other provisions on other platforms.

Change history

modified May 25, 2026

Current version removes specific language about rolling reserves withholding transaction amounts and simplifies the hold rationale to general liability protection, broadening PayPal's discretion.

View full change record →

Consumer impact (what this means for users)

Under this clause, if PayPal limits or terminates an account, the account balance may be held for up to 180 days before being released, with held funds used to satisfy chargebacks, claims, fees, or penalties that arise during that period. This applies to both personal and business account holders.

How other platforms handle this

Glassdoor Medium

If we become aware that a child has provided us with personal data without parental consent, we remove such data and terminate the child's account (except where we are required to retain all or a portion of such data for compliance purposes).

Wyze Medium

we have adopted a policy of terminating, in appropriate circumstances, the accounts of users who repeatedly infringe the intellectual property rights of others.

Skillshare Medium

If we learn that we've collected the personal data of a child under the age of 13 or 16, as applicable, we'll take reasonable steps to delete the personal data. This may require us to delete the Skillshare account...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
If we limit your account, funds may be held in your account for up to 180 days if necessary to protect against the risk of reversals, chargebacks, claims, fees, fines, penalties and other liability.

Excerpt from PayPal's User Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

EFTA / Reg E
United States Federal
FTC Act Section 5
United States Federal
GLBA
United States Federal

Provision details

Document information
Document
PayPal User Agreement
Entity
PayPal
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013152
Document ID
CA-D-00044
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3d68439fe78dc8e9c5af9b89ed2de54f7c5988ef4a3e224a5424db99720a851e
Analysis generated
May 21, 2026 05:39 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: PayPal
Document: PayPal User Agreement
Record ID: CA-P-013152
Captured: 2026-05-21 05:39:46 UTC
SHA-256: 3d68439fe78dc8e9…
URL: https://conductatlas.com/platform/paypal/paypal-user-agreement/provision/CA-P-013152/fund-hold-on-account-limitation-or-termination-up-to-180-days/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does PayPal's Fund Hold on Account Limitation or Termination (Up to 180 Days) clause do?

This provision creates a significant liquidity risk for business users who rely on PayPal balances for operational cash flow, as the agreement reserves the right to withhold funds for up to 180 days following an account limitation or termination triggered by PayPal's assessment of risk or policy violation.

How does this clause affect you?

Under this clause, if PayPal limits or terminates an account, the account balance may be held for up to 180 days before being released, with held funds used to satisfy chargebacks, claims, fees, or penalties that arise during that period. This applies to both personal and business account holders.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 277 platforms. See the full comparison.

Is ConductAtlas affiliated with PayPal?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by PayPal.