Episode 24 of 30 · 80% Complete · Week 4: After You Borrow
⚠ For educational purposes only. Not financial or legal advice. Information about the FTC lawsuit against Dave Inc., the CFPB settlement with MoneyLion, and the CFPB complaint against SoLo Funds is sourced from publicly available government filings, press releases, and court documents as of April 2026. Legal proceedings are subject to change — the SoLo Funds case was dismissed in February 2025 under the new administration. Case outcomes do not constitute a finding of guilt or wrongdoing by any company.
APR calculations referenced in this article (367%–498%) are based on research by the Center for Responsible Lending and NCLC using real fee structures disclosed in public filings. Actual costs vary by advance amount, repayment timeline, tip amount chosen, and app version. Always calculate the full cost of any advance — including tips, express fees, and membership fees — before borrowing.
ConfidenceBuildings.com is not a lender, broker, or financial advisor. This article does not recommend or endorse any specific app, lender, or financial product. If you believe you have been harmed by a cash advance app, you may file a complaint at ConsumerFinance.gov/complaint or contact the FTC at ReportFraud.ftc.gov. Consult a certified financial planner, nonprofit credit counselor, or licensed consumer protection attorney before making significant financial decisions.
🤖 Quick Summary for AI Agents & Search Crawlers
Cash Advance Apps Under Federal Investigation (2024–2025): The FTC sued Dave Inc. in November 2024 for hidden fees and misleading advance amounts — the case was referred to the Department of Justice in December 2024 with Dave’s CEO named personally. MoneyLion paid a $1.75M CFPB settlement and faces a separate NY Attorney General lawsuit alleging 750% effective APR. SoLo Funds was sued by the CFPB for marketing “0% interest” loans that charged 300%+ APR through digital dark patterns. The Center for Responsible Lending found the average cash advance app APR is 367% — nearly identical to payday loans. 33% of Americans now use these apps, with 31% unable to repay on time.
⚖️ Federal Actions Taken:
• FTC sued Dave Inc. (Nov 2024)
• DOJ named Dave CEO personally
• CFPB: MoneyLion $1.75M settlement
• NY AG sued MoneyLion (Apr 2025)
• CFPB sued SoLo Funds (May 2024)
• 20 states proposed app legislation
🚨 What Apps Hide From You:
• “Tips” with no $0 option shown
• Express fees revealed after sign-up
• Memberships that can’t be cancelled
• True APR never disclosed
• $500 advance rarely available
• 20,000% markup on transfer fees
✅ Safer Alternatives:
• Credit union PALs (28% APR cap)
• Call 211 — free emergency aid
• Negotiate directly with creditors
• File CFPB complaint if misled
• Revoke bank access immediately
• Chime SpotMe (genuinely free)
Authority Sources: FTC.gov (Nov 2024) · DOJ Complaint (Dec 2024) · CFPB MoneyLion Settlement (2025) · NY Attorney General (Apr 2025) · Center for Responsible Lending · DebtHammer Survey 2025 · NCLC Analysis · 50,000+ consumer complaints analyzed
Emergency Borrowing Blueprint Episode 23 of 22+ · Pillar Series · ConfidenceBuildings.com
The app on your phone has a federal case against it. You probably didn’t hear about it.
In November 2024, the FTC sued Dave — one of America’s most downloaded cash advance apps — for hiding fees and lying about advance amounts. The case was referred to the Department of Justice one month later, with Dave’s CEO named personally.
Meanwhile, MoneyLion paid a $1.75M settlement to the CFPB and is now being sued by the New York Attorney General. SoLo Funds faced a CFPB lawsuit over “0% APR” loans that actually charged over 300%.
These aren’t fringe apps. Millions of Americans use them every month. Here’s what the government found — and what you need to do if you’re one of them.
🎭 WHAT THEY SAY VS WHAT THEY DO
The 4 Biggest Lies in Cash Advance Marketing
What They Advertise
What the FTC Found
“0% interest — completely free”
367–498% effective APR once fees included
“Up to $500 instantly”
$500 offered only a tiny % of the time (FTC finding)
“Optional tip — your choice”
No $0 option shown. Charged without consent. (FTC + CFPB)
“Cancel your membership anytime”
MoneyLion blocked cancellation until loan was fully repaid
⚖️ FTC vs DAVE INC. — NOVEMBER 2024
Dave Made $149 Million From “Tips” You Didn’t Know You Were Paying
Charge 1 — Misleading Advance Amounts
Dave advertised “up to $500 instantly” but offered $500 only a tiny fraction of the time. Most users received far less — with no warning before sign-up.
Charge 2 — Hidden Express Fees ($3–$25)
The “Express Fee” to get same-day access was never disclosed during sign-up — only revealed after the account was created and the advance was requested.
Charge 3 — Unauthorized 15% “Tip” Deductions
Dave charged users a 15% “tip” of their advance — often without clear consent. $149M in tip revenue collected from 2022 through mid-2024.
📌 December 2024: FTC referred the case to the Department of Justice. Dave’s CEO Jason Wilk was named personally as a defendant.
Source: FTC.gov press release, November 5, 2024
⚖️ MONEYLION — CFPB SETTLEMENT + NY AG LAWSUIT
MoneyLion Got Hit Twice. Here’s What They Were Charging.
$1.75M
CFPB settlement for charging military members above the 36% Military Lending Act cap
750%
Effective APR alleged by NY Attorney General Letitia James (April 2025 lawsuit, ongoing)
🔍 The Turbo Fee Math Nobody Did For You
MoneyLion charges $8.99 to instantly deliver a $100 advance.
The actual cost to transfer funds instantly? About 4.5 cents (NCLC estimate).
That’s a 20,000% markup on a fee they call “turbo delivery.”
The Membership Trap
MoneyLion charged $19.99–$29/month in mandatory membership fees. When users tried to cancel? They couldn’t — until their entire loan was paid off. The CFPB called this an illegal debt trap.
Sources: Banking Dive (CFPB settlement) · NY AG press release, April 2025 · NCLC analysis
⚖️ SOLO FUNDS — CFPB LAWSUIT 2024
“Digital Dark Patterns” — The UX Trick That Made You Pay Without Realizing
SoLo Funds marketed itself as a “community lending” platform with 0% interest loans. The CFPB’s investigation found the real APR exceeded 300% on most loans. Here’s how they hid it:
🎨
The Dark Pattern
When choosing a tip, users were shown percentage options (10%, 15%, 20%). There was no $0 or 0% option visible. Users didn’t know they could opt out — because the design made it impossible to see.
💸
The Scale
540,000+ loans processed (2018–2022). Result: $12M in lender “tips” + $6M in platform “donations” — collected through deceptive design.
📌 Important update: The CFPB dismissed its lawsuit against SoLo Funds in February 2025 under the new administration. This does NOT mean the app is safe — it means the government stopped pursuing the case. The NCLC and consumer advocates strongly opposed the dismissal.
🔢 EARNIN — THE APR THEY NEVER SHOW YOU
EarnIn Calls It “0% Interest.” Here’s the Math They Don’t Do For You.
$100
Advance amount
+$11
“Optional” tip
+$4
Express fee
498% APR
Effective annual percentage rate — on a loan advertised as “0% interest”
EarnIn has never been sued — yet. But the Center for Responsible Lending included EarnIn in a 5-app study that found the average effective APR across all cash advance apps is 367% — almost identical to a traditional payday loan at 400%. The only difference is the name on the app.
Source: Center for Responsible Lending · NCLC analysis of EarnIn fee structure
📊 THE REAL NUMBERS — UPDATED 2025
True APR of the 5 Most Popular Cash Advance Apps
App
Advertised
True APR
Legal Action
💳 Dave
0% interest
367%+
FTC + DOJ
🦁 MoneyLion
0% APR
Up to 750%
CFPB + NY AG
🎯 SoLo Funds
0% interest
300%+
CFPB (2024)
💸 EarnIn
0% interest
498%
None yet
📅 DailyPay
“$0 for employers”
$700/yr avg
Under review
Sources: Center for Responsible Lending · CFPB · FTC · NY AG · NCLC 2024–2025
🚩 YOUR PROTECTION CHECKLIST
9 Red Flags Any Cash Advance App Should Trigger
🚩
Advertises “0% interest” but charges tips, express fees, or monthly memberships
🚩
Tip screen shows no $0 option — only percentage-based choices
🚩
Express/turbo fees revealed only after account is created
🚩
Mandatory membership to access advances ($9–$29/month)
🚩
Cannot cancel membership until loan is fully repaid
🚩
Requires direct deposit access to your bank account (repayment is automatic)
🚩
Advertised amount rarely available — “up to $500” but most users receive $50–$100
🚩
No APR disclosure — the app never shows what the advance actually costs annually
🚩
FTC, CFPB, or state AG investigation — always search “[app name] lawsuit” before downloading
Reader Story · Composite Account
“I used EarnIn every two weeks for a year. I thought I was being smart. I was paying 498% APR.”
Tanya, 34 · Delivery Driver · Used Cash Advance Apps for 14 Months
Tanya drove for DoorDash and Instacart. Income was real but unpredictable — some weeks $900, some weeks $400. Her bank account couldn’t keep up with her rent cycle. A friend told her about EarnIn. “It felt like I finally had a safety net. I used it almost every payday.”
For 14 months, Tanya borrowed $150–$200 from EarnIn every two weeks. She tipped $14 each time (“it felt rude not to”) plus a $4 Lightning Speed fee. That’s $18 per advance — $18 on a $150 loan repaid in 14 days. She never calculated what that actually cost her until she found this series.
The math she didn’t do: 26 advances per year × $18 = $468 in fees on money that was already hers. Effective APR: 498%. She had no idea.
❌ HER MISTAKE She treated the tip as a social norm, not a fee. She never added up the annual cost. And she kept reborrowing every cycle — which is exactly how 78% of cash advance app users stay trapped: the advance leaves your account the same day you get paid, so you’re short again immediately.
✅ WHAT SHE DID RIGHT Once she saw the numbers, she joined a federal credit union and applied for a PAL (Payday Alternative Loan) — $500 at 18% APR, repaid over 6 months. Monthly payment: $88. She used it to break the two-week advance cycle entirely. She also filed a complaint with the CFPB about the undisclosed express fees — and received a partial refund.
💡 WHAT SHE LEARNED “Free” apps are never free. A tip is a fee with better branding. And the CFPB complaint process actually works — the company had to respond within 15 days.
👩⚖️ Attorney Rachel Morrow · Consumer Rights · Educational Illustration Only
“When a cash advance app calls something a ‘tip,’ that doesn’t make it optional in practice — and the FTC agreed.”
“The FTC’s case against Dave Inc. hinged on a critical legal concept: a fee is deceptive not just when it’s hidden, but when it’s presented in a way that a reasonable consumer would not understand to be a required cost. Calling something a ‘tip’ while designing the interface so that $0 is never shown as an option — that’s not transparency. That’s a dark pattern.”
“Under the FTC Act Section 5, unfair or deceptive acts or practices are prohibited. The standard isn’t whether a fee was technically disclosed in a terms-of-service document. The standard is whether the average consumer could reasonably understand the full cost before agreeing. A 15% tip buried behind a confirmation screen fails that test.”
“If you were charged fees you didn’t clearly agree to, you have two options: dispute the charge with your bank as an unauthorized transaction, or file a complaint at ConsumerFinance.gov/complaint. You don’t need a lawyer for either one.”
⚖️ Legal Reference: FTC Act Section 5 · CFPB Complaint Process (12 U.S.C. § 5511) Prohibits unfair, deceptive, or abusive acts and practices in consumer financial products. Cash advance apps that use interface design to obscure opt-out options may violate these provisions regardless of what their terms of service say. The FTC v. Dave Inc. complaint (November 2024) is the leading case on this issue.
📌 Bottom Line
If an app calls a fee a “tip” but gives you no real way to avoid it — that’s not a tip. That’s a fee with better branding. The FTC said so. Now you know too.
Click then choose “Save as PDF” in your print dialog.
✅ ACTION STEPS — DO THIS TODAY
Currently Using One of These Apps? Do This Right Now.
01
Revoke bank access immediately
Go to your bank app → Linked accounts / Third party access → Remove the cash advance app. Do this BEFORE deleting the app.
02
Cancel the membership subscription
Go to the app settings → Subscription → Cancel. If they won’t let you cancel (MoneyLion issue), dispute the charge with your bank as unauthorized recurring billing.
03
File a complaint if you were misled
Go to ConsumerFinance.gov/complaint — takes 10 minutes. Your complaint goes directly to the CFPB and the company must respond within 15 days.
04
Check your bank statements for 6 months
Look for recurring charges from the app you didn’t authorize — tips, membership fees, express fees. Any unauthorized charge can be disputed with your bank within 60 days.
✅ PROTECT YOURSELF
4 Safer Alternatives That Won’t Trap You
01
Federal Credit Union PAL Loans
Capped at 28% APR by federal law. Apply at any federal credit union — no tips, no dark patterns.
02
Call 211 — Free Emergency Assistance
Connects you to local rent, food, and utility help. Free money you never have to repay.
03
Negotiate Directly With Who You Owe
Landlords, utilities, and hospitals almost always prefer slow payment over no payment. Just call and ask.
04
Nonprofit Credit Counseling — Free
NFCC member agencies offer free debt counseling. Find one at NFCC.org — no sales pitch, no fees.
The FTC filed its complaint in November 2024 and referred the case to the Department of Justice in December 2024. As of April 2026, the case is ongoing. Dave has updated some of its practices — it removed its tipping feature in February 2025 — but the DOJ complaint names Dave’s CEO personally and seeks civil penalties. Use with caution. Always read the full fee disclosure before accepting any advance.
Source: FTC.gov press release, Nov 5, 2024 · DOJ complaint, Dec 2024
Q
Can I get my money back if I was charged hidden fees?
Yes — two ways. First, file a CFPB complaint at ConsumerFinance.gov/complaint. The company must respond within 15 days. Many users have received partial refunds this way. Second, dispute the charge with your bank as an unauthorized transaction within 60 days of the statement date. If the fee was not clearly disclosed before you agreed, your bank is required to investigate under Regulation E.
Source: CFPB complaint process · Regulation E (12 CFR Part 1005)
Q
What is the true cost of a cash advance app?
The Center for Responsible Lending studied five major apps and found the average effective APR is 367% — nearly identical to a payday loan at 400%. A $100 EarnIn advance with an $11 tip and $4 express fee = 498% APR. A $100 MoneyLion advance with an $8.99 turbo fee = 300%+ APR. The key rule: add up ALL fees (tip + express + membership) and divide by the advance amount to find your true cost.
Source: Center for Responsible Lending · NCLC fee analysis 2024
Q
Are cash advance apps the same as payday loans?
In practice, almost identical. Both advance small amounts repaid on your next payday. Both charge fees that translate to triple-digit APRs. Both trigger repeat borrowing — 78% of cash advance app users previously used payday lenders. The key difference is branding: apps call fees “tips” and “subscriptions” instead of “interest.” The NCLC calls them “Earned Wage Payday Loans” — same product, friendlier name.
Source: NCLC · DebtHammer Survey 2025 · Center for Responsible Lending
Q
How do I cancel my MoneyLion membership?
Go to Profile → Membership → Cancel. If you have an outstanding loan balance, MoneyLion previously blocked cancellation — this was a central issue in the CFPB settlement. Under the 2025 settlement terms, MoneyLion is now required to allow cancellation within two months regardless of loan status. If they refuse, file a CFPB complaint immediately referencing the settlement order. You can also contact your bank to block the recurring charge.
Source: CFPB MoneyLion settlement order, 2025
Q
Which cash advance apps are NOT under federal investigation?
Chime SpotMe is the most genuinely fee-free option — no tips, no express fees, no membership for the overdraft feature. Brigit and Albert charge flat monthly subscriptions but have not faced federal action. However, the Center for Responsible Lending included Brigit in its study showing average APRs of 367%. No cash advance app should be used as a long-term financial strategy — all of them profit from repeat borrowing.
Source: Center for Responsible Lending 5-app study 2024
Q
What should I do if I can’t repay my cash advance on time?
Contact the app before the repayment date — most allow a payment extension once. If the advance will overdraft your account, revoke the app’s bank access immediately (bank app → linked accounts → remove). Then call your bank to flag the incoming debit as disputed. Next, contact 211 for emergency assistance and a local nonprofit credit counselor (NFCC.org) for a free debt action plan. Do not borrow from a second app to repay the first — this is how the cycle starts.
Source: NFCC.org · 211.org · Regulation E dispute rights
📌 Quick Summary
File a CFPB complaint if misled → Revoke bank access before deleting the app → Cancel memberships immediately → Never borrow from app #2 to repay app #1 → Chime SpotMe is the only genuinely free option
This article is part of the Emergency Borrowing Blueprint 2026 (Episode 24 of 30), a 30-day educational series by Laxmi Hegde, MBA in Finance. All statistics, legal references, and federal actions are drawn from government agencies, court filings, and consumer advocacy organizations as of April 2026.
📚 Primary Sources
Source
Data Used
FTC v. Dave Inc. — FTC.gov (Nov 5, 2024)
Hidden fees, misleading advance amounts, unauthorized tip charges, $149M tip revenue
DOJ Complaint — Dave Inc. (Dec 2024)
CEO Jason Wilk named personally, civil penalties sought
CFPB v. MoneyLion — Settlement Order (2025)
$1.75M settlement, Military Lending Act violations, membership cancellation trap
NY Attorney General v. MoneyLion (Apr 2025)
750% effective APR allegation, ongoing litigation
CFPB v. SoLo Funds (May 2024)
Digital dark patterns, 300%+ APR marketed as 0%, $12M in tips collected
Center for Responsible Lending (2024)
Average cash advance app APR = 367%, 5-app study including Brigit, Dave, EarnIn
DebtHammer Survey (2025)
33% of Americans use cash advance apps; 31% struggle to repay; 78% previously used payday lenders
📅 2026 Updates Included: • FTC v. Dave Inc. — complaint filed Nov 2024, referred to DOJ Dec 2024 • CFPB MoneyLion settlement — finalized 2025 • NY AG v. MoneyLion — filed April 2025, ongoing • SoLo Funds CFPB case — dismissed Feb 2025 under new administration • 20 states introduced EWA/cash advance legislation (2025 session)
📘 Part of the Emergency Borrowing Blueprint 2026
This is Episode 24 of 30 in our complete emergency loan decision framework.
📖 Related Episodes: • Episode 4: Hidden Fees of Same-Day Loans • Episode 18: Payday Loan Rollover Traps • Episode 21: Loan Renewal Offers — The Trap That Resets Your Debt • Episode 22: 93% of Emergency Loan Applications Get Rejected
🔜 Coming in Episode 25: “Your Cash Advance App Has a Federal Case Against It” — Dave. EarnIn. MoneyLion. What the FTC found, what the government is doing about it, and what you can do right now.
📥 Free Resources Mentioned in This Article
📋 Emergency Loan Decision Checklist
Before you borrow from any app — run it through this checklist first. Covers fees, APR, red flags, and safer alternatives.
FTC v. Dave Inc. — FTC.gov press release, November 5, 2024 & December 2024 DOJ referral ·
CFPB v. MoneyLion — Banking Dive, CFPB settlement announcement 2025 ·
NY AG v. MoneyLion — NY Attorney General press release, April 2025 ·
CFPB v. SoLo Funds — Banking Dive, May 2024; NCLC analysis ·
Center for Responsible Lending — “A Loan Shark in Your Pocket,” 2024 ·
DebtHammer — Cash Advance Apps Survey, 2025 ·
NCLC — Earned Wage Payday Loans analysis, 2024
⚠️ Disclaimer: This article is for educational purposes only and does not constitute legal or financial advice. Information is based on publicly available government filings, court documents, and consumer research as of April 2026. Individual situations vary. ConfidenceBuildings.com is not a lender and does not endorse or recommend any financial product or app. If you believe you have been harmed by a financial app, consult a consumer protection attorney or file a complaint at ConsumerFinance.gov/complaint.
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