“We have made the decision to end our relationship with you.”
If you got that email, you already know the phone call goes nowhere. The person you reach is not being evasive. They are legally prohibited from telling you why.
What actually happened
Every bank, and every fintech that sits on top of a bank, runs a Bank Secrecy Act program. When the software sees a pattern it has been trained to flag, a human decides whether to file a Suspicious Activity Report. Under federal law (31 U.S.C. 5318(g) and 12 CFR 21.11), a bank cannot tell you that a SAR was filed, or that one was considered, or that one exists. The same law protects the bank from being sued for filing one. So the rational move for a compliance team is: file, close, say nothing.
Fintechs close faster than banks. Chime, Cash App, Varo, and Current are not banks; they are programs running on a sponsor bank, and the sponsor’s regulator holds the sponsor accountable for every program’s customers. The economics are a few dollars a month from you versus a possible regulatory finding, so risk tolerance is near zero and closure is the default. ProPublica documented this in 2021: Chime drew 197 complaints to the CFPB about closed accounts in a year, against 317 for Wells Fargo, a bank with roughly six times the customers. In 2024 the CFPB fined Chime for holding customers’ balances for weeks or months after closing their accounts.
What the software is looking for
FinCEN publishes the patterns it wants banks to watch. Nothing in them mentions arrangements. But read the red flags from the 2014 and 2020 human-trafficking advisories and the May 2026 notice on payments for commercial sex:
- “A customer regularly receives multiple P2P transfers from accounts with which the customer has no previous transactional relationships and for which there is no business or apparent lawful purpose.”
- Memo lines with “vague references” such as “services,” “donation,” “personal care,” “link.”
- Spending inconsistent with the customer’s profile, especially hotels and travel.
- Frequent cash deposits with no payroll or ACH income.
- Cash deposits kept just under $10,000.
- Multiple unrelated people sending money to the same recipient.
A 23-year-old with no payroll deposits, $3,000 a month arriving by Zelle from two or three different men with memos like “for you,” an occasional cash deposit, and a hotel charge in another city matches five of those without doing anything illegal. The model does not know she is in a relationship. It knows she matches a typology.
The honest fix
None of this is about hiding. It is about being legible.
- One traditional bank, opened at a branch, kept for years. A branch relationship is a form of legibility. Not a fintech.
- Consistent rails. Bank transfer, ACH, or Zelle from the same sender on the same cadence. Wires are cleanest of all.
- Plain memo lines or none. “Monthly support” is fine. “Services,” “donation,” “wellness” are on FinCEN’s list.
- Never split a deposit. Cash over $10,000 in a day triggers a report; that report is a form, not an accusation. Depositing $6,000 today and $6,000 tomorrow to avoid it is structuring, a federal crime carrying up to five years regardless of where the money came from.
- Prefer non-cash. If someone insists on cash, deposit it whole, on a schedule, and keep a written record of where it came from.
- Friends-and-family, not goods-and-services, on Venmo, PayPal, and Cash App.
- Keep the account boring. A part-time job’s direct deposit, rent, groceries. An account with ordinary life in it reads as an ordinary life.
- Keep records. A bank that asks “what is this money?” gets a calm, accurate answer: “support from my partner.” That answer, with a record behind it, ends most reviews.
- Know your Zelle limits. Wells Fargo: $3,500 per rolling day, $20,000 per rolling month. Bank of America: $1,000 a day for the first 30 days after enrolling, $2,000 for days 31 to 60, $3,500 after that, $20,000 a month. A sender who bumps into a limit and immediately tries another app is a velocity pattern.
- Never move money for anyone else. “Can you receive this and send it to my friend” is either a scam or money laundering, and either way it is your account that closes.
When the email comes anyway
Do not argue on the phone; they cannot tell you and will not reverse it. Ask for your balance in writing; if it takes more than 14 days, file a CFPB complaint at consumerfinance.gov/complaint (the Chime order was about exactly this). Download every statement before you lose access. Open the next account at a branch, not another fintech. And know that since August 2025 there is an executive order directing regulators to stop banks from closing accounts over “reputational risk” and to review past closures. It does not get your account back. It does mean “we didn’t like the pattern of your deposits” is no longer an unchallengeable reason.
What this article will not tell you
How to avoid a cash report. How to disguise where money came from. How to keep a bank from filing anything. Those questions have one answer, “don’t,” and anyone selling a different answer is selling you a felony.
Sources: 31 U.S.C. 5318(g); 12 CFR 21.11; 31 U.S.C. 5324; 31 CFR 1010.311; FinCEN advisories FIN-2014-A008 and FIN-2020-A008 and the May 2026 FinCEN notice; ProPublica, “Chime,” July 2021; CFPB consent order against Chime, May 2024; Wells Fargo and Bank of America Zelle terms. General education, not legal or financial advice.