Neobank Dave Issues Statement Regarding CFPB Proposal, an Interpretive Ruling Around Paycheck Advance and EWA

Dave Inc. (Nasdaq: DAVE), one of the nation’s neobanks, has recently issued a statement regarding a proposal from the Consumer Financial Protection Bureau (CFPB).

Dave’s management has stated:

“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.”

Jason Wilk, Founder and CEO of Dave added:

“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.”

As covered, Dave claims that it is “a leading U.S. neobank and fintech pioneer serving millions of everyday Americans.”

Dave explains that is “uses disruptive technologies to provide best-in-class banking services at a fraction of the price of incumbents.”

Dave says that it partners with Evolve Bank & Trust, a FDIC member.

In May of this year, Dave Inc. reported its financial results for the first quarter ended March 31, 2024.

Jason Wilk, Founder and CEO of Dave had noted:

“2024 is off to a strong start as we exceeded growth and profitability expectations in the first quarter. Member acquisition remained strong and efficient in spite of seasonal softness associated with tax refund season, and member retention expanded meaningfully which collectively drove 14% year-over-year growth in our monthly transacting member base. Expanding our base beyond the 2.1 million transacting member inflection point for profitability we achieved last quarter positioned us to generate a 32% increase in Adjusted EBITDA relative to Q4.”

As mentioned in the update:

“Despite the seasonal patterns which typically temper ExtraCash demand in the early part of the year, we originated over $1 billion in ExtraCash advances during Q1, up from Q4 and a 32% increase from Q1 2023, while we continued to markedly improve credit performance as a result of our CashAI underwriting engine. We plan to continue delivering value for both Dave customers and shareholders as we further solidify Dave as the superior banking solution for everyday Americans in 2024.”


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