Reported Earlier, Dave Comments On CFPB Proposal, Asserts ExtraCash Product Complies With Overdraft Regulatory Framework
"We are closely monitoring the recently proposed interpretive ruling from the CFPB around paycheck advance and earned wage access ("EWA"), a model which Dave was originally founded on, but transitioned away from beginning in 2022 due to a lack of certainty around the regulations," said Jason Wilk, Founder and CEO of Dave. "Dave's ExtraCash product is structured as a bank-originated overdraft with optional fees, which combats the excessive fees found at incumbent banks. As a result, we believe ExtraCash and our optional fees sit within the overdraft regulatory framework that is distinguished from EWA and paycheck advance products."