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Its down to how the payment was SENT to your account.
1. If he sent using money > goods / services option then paypal would see you as a seller and may apply the new seller hold. They would also charge you a fee.
2. If he had sent using the send money > family / friends option then you would normally have had the payment instantly with no fee.
Well you haven't said which of those 2 options he used to send you the funds have you?
New seller hold.
Normally a security review of about 24 hours for a 'friends / family' payment.