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SB 1125

Consumer Protection - As introduced, prohibits an online payment system from freezing the funds of a user without first providing the user with a written notice of the online payment system's intent to freeze the user's funds; designates a violation as an unfair or deceptive act or practice pursuant to the Tennessee Consumer Protection Act of 1977. - Amends TCA Title 45 and Title 47, Chapter 18.

114th Regular Session (2025-2026) Introduced by Ken Yager

Tennessee bill requires online payment systems to notify users in writing before freezing funds, enforceable as consumer protection violation.

Assigned to General Subcommittee of Senate Commerce and Labor Committee
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Bill Summary · SB 1125

Legislative bill overview

SB 1125 requires online payment systems (like PayPal, Stripe, Square, etc.) to provide written notice to users before freezing their funds. The bill classifies violations as unfair or deceptive practices under Tennessee's consumer protection law, enabling enforcement action and potential penalties.

Why is this important

Online payment platforms have significant discretion to freeze accounts for suspected fraud, violations of terms of service, or regulatory concerns—sometimes leaving users without access to their money for extended periods. This bill attempts to add procedural protections by requiring advance notice, giving users an opportunity to respond or take action before their funds are locked. This addresses a real consumer pain point, particularly for small business owners and gig workers who depend on these platforms for cash flow.

Potential points of contention

  • Business operational concerns: Payment processors argue that advance notice before freezing funds could enable fraud, money laundering, or illicit activity to continue or be concealed. They may claim immediate action is sometimes necessary for compliance and risk management.
  • Regulatory overlap: Federal financial regulations (FinCEN, banking law) already govern certain freeze situations. The bill doesn't clarify how state consumer protection rules interact with federal anti-money laundering or sanctions compliance requirements.
  • Definition ambiguity: The bill doesn't specify what constitutes adequate "written notice" (email? SMS? snail mail?), timing requirements before freezing, or exceptions for emergencies, creating potential enforcement disputes.

Compiled from official sources — confirm details with the bill’s official record.

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