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Its down to how the payment was SENT to an account.
1. If sent using money > goods / services option then paypal would see the recipient as a seller and apply the new seller hold. They would also charge a fee.
2. If sent using the send money > family / friends option then the recipient would have the payment instantly (as long as it wasn't an echeque pending with a clearance date) with no fee if funded from a bank account or balance (a fee if you use a card). (However that option is not available in every country).
Sadly if she used option 1 then you need to read the link for payment release.
https://www.paypal.com/us/smarthelp/article/my-payment-is-on-hold.-why-is-this-happening-faq3297
Advice is voluntary.
Kudos / Solution appreciated.
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