Reported Earlier, Dave Comments On CFPB Proposal, Asserts ExtraCash Product Complies With Overdraft Regulatory Framework
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."
“我们密切关注CFPb最近提出的有关发薪日预支和工资赚取（EWA）的解释性裁决，这是Dave最初建立的模式，但由于对监管缺乏确定性，从2022年开始过渡，”Dave的创始人和首席执行官Jason Wilk表示。“Dave的ExtraCash产品结构类似于银行发起的透支，可选择收取费用，这有助于应对现有银行的过度收费。因此，我们认为ExtraCash和我们可选的费用符合透支监管框架，与EWA和发薪日预支产品有所区别。”