Chase closed my savings account without notification

So because my bank is closing, I opened an account with Chase on Saturday (4/17). Today, I tried to check the status of my transfers and was informed that Chase locked my accounts for security concerns, and to call them to straighten things out. I was informed over the phone that the bank was going to close the accounts, I would never be able to bank with Chase again, and she had no information as to why. I have never had a bounced check, overdrawn account, or an unpaid fee with any bank. I wanted to know:

A. Are they allowed to close my account without notice?

B. what can I do?

C. Do they have to tell me why?

Uniswap founder Hayden Adams announced that his banker, JPMorgan Chase, closed his accounts without giving notice or a reason for the closure. He made this known in a tweet and added that he wasn’t the only one suffering the same fate.

JPMorgan Closes Adams Account

According to him, many companies and individuals with affiliations to the crypto industry have suffered the same.

🤡 This week @jpmorgan @Chase closed my bank accounts with no notice or explanation

🧑‍💻 I know many individuals and companies who have been similarly targeted simply for working in the crypto industry

🚀 Thanks for making it a personal

— hayden.eth 🦄 (@haydenzadams) January 23, 2022

The move comes months after a report revealed that the US Securities and Exchange Commission (SEC) had opened investigations on Uniswap Labs. Uniswap Labs is the major developer behind the Uniswap protocol, the largest decentralized exchange in the world.

The investigation became public in November when Wall Street Journal reported that SEC officials were looking at how investors use the DEX. Uniswap Labs spokesperson at the time reiterated the company’s commitment to working with regulators and complying with relevant laws.

Why the Bank Probably Closed his Account

There have been several hypotheses as to what could have led to this move by the banks. According to the former chairman of US Commodity Futures Trading Commission (CFTC), Brian Quintenz, this might be a “shadow de-banking of crypto” by the authorities. 

Likely a shadow de-banking of crypto by @federalreserve or @USOCC bank examiners, with direction from the top. If the examiner told a bank that a certain customer is too risky and the bank ended that relationship, the bank is contractually prevented from telling that customer why

— Brian Quintenz (@BrianQuintenz) January 23, 2022

The ex-government official who’s now an advisory partner at Andreessen Horowitz tweeted that the directive could be from bank examiners such as the Federal Reserve or The Office of Comptroller of the Currency. 

These agencies can direct a bank to close an account because the customer is too risky. In such cases, the bank can’t disclose its reason for closing the account.

JPMorgan’s History of Account Closure

As Adams stated, this isn’t the first time the bank will do something like this. For example, the bank closed the payroll account of crypto exchange Kraken with only a five days’ notice.

In 2018, it also shut down Erik Voorhees’s account. Erik Voorhees is the founder of the crypto exchange ShapeShift. The bank also shut down accounts belonging to Bitcoin mining firm Compass Mining in 2019.

These moves from the bank make it difficult to understand its stance towards crypto. While it’s closing down crypto affiliated accounts, it has also been taking on a crypto exchange such as Coinbase and Gemini as customers. Beyond that, the bank also offers its wealthy clients access to crypto investment funds. 

Reports continue to trickle in from people who report that Chase closed down all of their accounts.  This often happens soon after opening a new Chase card.  Sometimes it happens after making a single very large purchase.  Sometimes it seems to be triggered by an abrupt increase in spend overall.

When people ask Chase why they were shut down, Chase often refers to the large number of accounts they opened (not just with Chase) in the past year.  Fortunately, Chase will sometimes review the decision and overturn it.

Why Chase shutdowns happen

This Reddit post offers a logical explanation for why Chase is shutting down accounts.  The theory is that Chase is actively trying to avoid Bust-out Fraud.  Bust-out fraud is where a fraudster builds up their credit with responsible credit card use and then suddenly runs up all of their balances before disappearing.  This Experian white paper describes the bust-out process as follows:

…the fraudster builds up a history of good behavior with timely payments and low utilization. Over time, he or she obtains additional lines of credit and requests higher credit limits. Eventually, the fraudster uses all available credit and stops making payments. Overpayments with bad checks are often made in the final stage of the bust-out, temporarily inflating the credit limit and causing losses greater than the account credit limit.

The problem for credit card rewards enthusiasts is that our behavior patterns often look exactly like these bust-out fraudsters, with the exception of the final fraudulent bust-out activity (which we don’t do!).

The old (but still relevant) shutdown reasons

The Experian white paper asserts that lenders typically look for suspicious activities to identify bust-out behavior:

Examples of suspicious activities are frequent convenience checks; frequent cash advances; multiple payments within one billing period from different accounts and different sources; purchases from high-risk, high-value merchants; and unusual purchase amounts (e.g., $1,000 at a dry cleaner). Some issuers use these factors in models to predict bust-outs.

Those who heavily manufacture spend often exhibit many of the above listed behaviors.  They are known to make multiple payments within one billing period, and they certainly make purchases in unusual purchase amounts.  Those who have been manufacturing spend heavily for a while are used to getting shut down for these activities.

The new shutdown reasons

The Experian white paper goes on to argue that predictive bust-out scores can be computed entirely from credit data:

…Issuers that only utilize internal transaction and payment data see only account activities in their own organization…

Credit reporting data provides a perspective on how account holders behave across the credit spectrum. Behaviors such as credit line increases, new accounts, changes in utilization and balance growth can all be captured through credit reporting data. By generating a wider perspective, the bust-out predictors can be observed months before the bust-out is executed…

I think it is safe to say that Chase has bought into this argument.  Whether or not they specifically use Experian’s bust-out scoring is irrelevant.  It’s clear from many datapoints that Chase is using credit reporting data and that shut-downs are often triggered by some of the behaviors Experian described above (credit line increases, new accounts, changes in utilization and balance growth).

Summary of Shut-Down Causes

Your accounts can be shut down due to suspicious spending activity (on your Chase cards), or suspicious patterns on your credit report which is collected across all of your accounts (not just Chase accounts).  Anecdotally it seems that applying for a new Chase credit card is one of the ways to ensure that Chase will evaluate you overall for suspicious activity.

Avoiding Chase shutdowns

The following advice is conjecture. I have no reasonable way to test this advice.

1. Keep your credit report clean

An ideal credit report shows a long credit history with no bad marks, few new inquiries, few new accounts, and a low credit utilization:

• Long credit history: Don’t cancel your oldest credit cards since closed accounts will eventually drop off your report. If you’re not using the cards anymore, product change them to no-fee cards and keep them alive with an occasional small purchase (some banks will close credit cards that have no activity after 6 months or so).
• Few new inquiries: When you apply for new credit cards, card issuers will submit a “hard inquiry” to one or more credit bureaus.  Unlike the other factors here, inquiries are not automatically shared across credit bureaus.  So, for example, your Experian report and Equifax reports will show different numbers of inquiries.  Therefore, one way to limit inquiry damage when applying for new cards is to spread out the inquiries.  Here are a few ways to accomplish that:
  • You can use the Credit Pulls Database to figure out which report a bank is likely to pull from before you apply, and avoid applying to those that are likely to push your inquiry count too high.
  • You can freeze the credit reports with high inquiry counts and ask the card issuer to pull from the report that wasn’t frozen (but they won’t always be willing to do so).  Doctor of Credit has a useful post about this technique here.
  • Often, applying for multiple cards from the same bank on the same day will result in only one credit inquiry on your credit report.  So, if you’re going to apply for a card anyway, you can get more bang for your buck by applying for two.  Our Best Offers page includes App Tips for each bank which indicate when the inquiries are combined.
• Few new accounts: Unlike inquiries, new accounts are usually shown on all three credit reports.  The obvious way to limit the number of new accounts is to rarely sign up for new cards.  Another option is to sign up for business cards which do not appear on personal credit reports.  You can find our automatically calculated Top N list of business card signup offers here.  Note that Capital One is an exception in that they do report business cards to the personal credit bureaus.  Barclays does too… sometimes.  It’s unclear when Barclays reports the cards and when they do not (if anyone has insight into this, please let me know!).
• Low credit utilization: Credit utilization is defined as the amount of credit available that you’ve used in a given month.  For example, if you have $100,000 in available credit and you charged a total of $5,000 within a month, then your utilization is only 5% (which is good).  Banks report credit used once per month to the credit bureaus, usually when your statement closes.  You can keep your utilization down by paying off some or all of the amount owed before your statement closes.  Keep in mind, though, that frequent intermittent payments can be a risk factor as well.  Also note that some banks report utilization on different schedules (see this Doctor of Credit post for more).

2. Keep your Chase card activity clean

As a reminder, Experian noted these suspicious activities: “frequent convenience checks; frequent cash advances; multiple payments within one billing period from different accounts and different sources; purchases from high-risk, high-value merchants; and unusual purchase amounts.”  That leads us to these obvious recommendations:

• Avoid convenience checks and cash advances: You should avoid these anyway. You won’t earn rewards from these cash advances, but you will have to pay fees and interest.
• Avoid multiple payments within one billing period from different accounts and different sources: Try to pay your Chase credit card bills from a single source and make just one or two payments per month.  If you are doing heavy manufactured spend that requires cycling your credit limit daily, then I recommend doing so with a different bank besides Chase. Pick one where you don’t mind getting shut down.
• Avoid purchases from high-risk, high-value merchants; and unusual purchase amounts: This one is a bit tougher in that we don’t know which merchants Chase considers to be high risk / high value.  But it is clear that a sudden flurry of large repeated purchases will look suspicious.  So, if you insist on using your Chase cards to buy gift cards, I recommend ramping up slowly over time.  A sudden jump in spend of this type will look suspicious.

3. Avoid signing up for new Chase cards if your credit report already looks suspicious

Chase continues to have many of the best signup offers, so I would never say to avoid Chase cards altogether.  However, if your credit report shows a large number of recent inquiries and new accounts, you may want to hold off. At least consider the risk when debating the pros and cons of getting a new Chase card.

Bottom Line

Chase has been shutting down accounts due to suspicious card activity and credit activity.  Reviews seem to be triggered, in part, by applying for new Chase cards.  Having too many new accounts on your credit report is a clear risk factor.  Unfortunately, we don’t know how many accounts is too many.  Nor do we know why some accounts are reinstated after review and others are not.  Hopefully following the recommendations given in this post will keep you safe.

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