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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. (However that option is not available in every country).
There are however some occasions where friends / family payments are held for reviews but these are normally only 24 hours.