Merchant account holds or full account freezes disrupt your cash flow and can make it difficult to conduct business. In this article, we'll take a look at both holds and freezes, why they happen, and what you can do about them. This article refers to account holds and freezes on funds from sales at a business. It does not refer to "account holds" for consumers, such as when purchasing gas using a debit card at the pump.
What are merchant account holds and freezes?
One of the most financially devastating things that can happen to a business is for a processing bank to freeze your merchant account. According to Matthew Klase, Esq., of law firm Webb, Klase & Lemond, LLC, "Most processors insert terms in their boilerplate contracts that give themselves wide discretion to hold back funds on a variety of grounds - excessive chargebacks, type of business the merchant is in, etc." If this happens, you won't be able to access the account and your funds from open authorizations will be held without deposit for an undisclosed period of time. This means that you can't accept new credit card transactions and the income from recently processed transactions will not be deposited for days, weeks, or longer. Unlike freezes, merchant account holds don't prevent you from continuing to accept cards. A merchant account hold or funds hold is when a credit card processor retains the money from specific credit card sales instead of depositing it into your account. Note that holds are different than ACH delays and rolling reserves. Both ACH delays and rolling reserves are risk mitigation tools for the processor. They're requirements imposed upfront as a condition of providing a merchant account to your business. By contrast, holds occur in response to a specific transaction or transactions. In other words, reserves are pre-emptive and holds are reactive.What causes merchant account holds?
There are a few reasons that a credit card processor may hold your funds:- Suspected fraud / suspicious processing behavior
- Breaking terms of your merchant agreement
- Investigating chargebacks
Suspected Fraud
Suspicious processing behavior is often the basis for a processor to put a hold on a business merchant account. Most of the time, processors are the second line of defense against credit card fraud, behind a business. Less commonly, if someone opens a merchant account with the intention of using it to defraud cardholders, processors become the first line of defense against fraud. Holds are imposed so that the processor can investigate potential fraud and protect cardholders. In some cases, legitimate transactions may be considered suspicious to a processor and lead to a hold. Most commonly, this happens with big jumps in processing volume in a short period of time. If you're a business with large seasonal swings, it's a good idea to give your processor a heads up before your busy season starts. Holds for suspected fraud are especially difficult because they’re typically applied by the processing bank without notice. Businesses only usually realize that their account has been held when they stop seeing deposits from credit cards sales.Breaking Terms
To open a merchant account, you must first sign a merchant service agreement. This agreement outlines the rules, fees, and limitations regarding processing volume and average ticket size for your account. If you break any of the provisions in your merchant service agreement, the processing bank can hold or even terminate your account. In the case of an account being held, it will be unusable for as long as it takes the processing bank to investigate the breach of the agreement and make a ruling on whether to reinstate or terminate the account. Common reasons why you may be found in violation of your merchant service agreement include:Excessive Chargebacks
Chargebacks are taken very seriously, and excessive chargebacks are a leading cause of merchant account holds and closures. A common misconception regarding chargebacks is that if you win, they don't count against you. That is simply not the case. Win or lose, a chargeback is a chargeback, and too many will lead to your merchant account being held or closed. We spoke with Chargebacks911, a risk mitigation firm managing more than 2 billion transactions annually to help online merchants optimize profitability through chargeback management, about how holds and chargebacks tie in. Cofounder and COO Monica Eaton-Cardone points out that chargebacks can lead to a processor imposing holds in the form of reserves. She explains that the best offense is a good defense. Eaton-Cardone recommends using anti-fraud tools, including AVS and 3D Secure, as well as verifying CVVs.Processing in Excess of Declared Volume and Average Ticket
When you apply for a merchant account, you'll declare your business's average monthly processing volume and your average ticket. Many people forget about these numbers once they start accepting cards, but processors don’t. These two figures are far more than a formality. Processing in excess of your declared volume or average ticket can lead to your account being held or terminated. It’s important to declare your processing amounts correctly and be familiar with merchant account processing limits and average tickets. If your processing volume or average ticket changes significantly, it's a good idea to contact your processor.Using a Merchant Account to Accept Payment for Undisclosed Goods or Services
Merchant accounts aren't a free pass to accept credit card payments for whatever you're selling on a particular day. When you apply for your merchant account, you provide a basic description of the goods or services that you're selling. Using the account to accept payment for anything outside of this description violates your agreement and may cause a hold or termination of your account. Additionally, some merchant agreements prohibit the sale of certain items or services. Some of the most commonly prohibited are pharmaceuticals, firearms, digital goods, travel services, telemarketing and more. Aggregators - like Square, Stripe, and PayPal - often have restrictions like this and keep public lists of prohibited business types. Some business owners sign up anyway, assuming that they're too small for a big company to catch. However, even aggregators with a faster sign up process often catch on. When they do, they'll freeze or close your account.Using a Merchant Account to Accept Payment for Other Businesses
Merchant accounts are issued to individuals or businesses for use by that party only. Using the account to accept payment for another person or business, sometimes called credit card factoring, is strictly forbidden. Once discovered, this behavior will almost certainly lead to account termination.Investigating Chargebacks
When a customer disputes a charge, the processor will remove the funds from that transaction from your account while the bank conducts an investigation. However, even if the chargeback goes in your favor, your processor may hold the funds instead of immediately returning them to you.What Doesn't Cause Holds
A common misconception is that personal credit can cause holds. While it's true that personal credit can have an effect on getting a merchant account, that will come up during the application process, not after you've begun processing. Additionally, if you have poor personal credit, there are other restrictions a processor may place on your account, such as rolling reserves, rather than allowing you to process and then holding the funds.When a Processor Suspects Fraud
Processors are obligated to take action against fraud and continually monitor all of their business clients for signs that a merchant account is being abused. If indications of fraudulent activity are detected, the offending merchant account will be held while an investigation is conducted to determine what triggered the alarm. Such investigations result in either the release of the merchant account hold or the termination of the account. If an investigation ends with the termination of a merchant account, additional actions may follow depending on the reason for the account closure. In the case of deliberate misuse or fraud, the offending merchant may be added to the terminated merchant file (TMF), face fines, or even have criminal charges brought against them. These fraud detection systems serve a vital purpose in the fight against fraud but they're not perfect. Sometimes innocent merchants have their accounts flagged and held.Avoiding Holds
Avoiding behavior that will trigger a processor’s fraud alerts can help prevent holds. There are a few guidelines for avoiding suspicious processing behavior: Contact your processing bank's risk department, not your sales representative, before running unusually large transactions. Attempting to process a large transaction beyond what is normal for your account will almost certainly lead to a hold. Keep your processor informed of changes in your business that will affect your processing behavior. One common change is carrying higher cost items that will increase your average ticket. For example, if a bait shop that has been selling only small bait and tackle items for years begins to sell deep sea fishing equipment, their average ticket that was previously $15 may spike to $500 or more overnight. This drastic change may lead to the processing bank holding funds until they investigate the reason for the ticket increase. Notifying your processing bank of changes in your processing behavior will allow them to adjust the ticket and volume figures for your account before there's an issue.What do I do if my merchant account is frozen?
If your account does end up getting frozen, there's not much that you can do except let the process run its course and cooperate with your processor. The processor will need to conduct their investigation and this will take time. In extreme cases where the cause of the hold is not deliberate and a substantial amount of funds are being held, you may wish to seek legal counsel from an attorney that specializes in bankcard law. Remember, the best defense against merchant account holds is a good offense. Be aware of your processing agreement terms, and limit any suspicious processing behavior to help avoid triggering your processor’s fraud alerts.
Ben Dwyer
Ben Dwyer began his career in the processing industry in 2003 on the sales floor for a Connecticut‐based processor. As he learned more about the inner‐workings of the industry, rampant unethical practices, and lack of assistance available to businesses, he cut ties with his employer and started a blog where he could post accurate information about credit card processing. As the blog gained in popularity, Ben began directly assisting merchants in their search for a processor. Ben believes in empowering businesses by providing access to fair, competitive pricing, accurate information, and continued support. His dedication to transparency and education has made CardFellow a staunch small business advocate in the credit card processing industry.
