# Direct-to-Consumer Paycheck-Advance Borrowers Paid $208 a Year in Fees and Tips

By Riza Dagoc

Canonical URL: https://www.tokenpost.com/news/regulation/34325
Published: 2026-10-18T10:39:56.000Z
Updated: 2026-10-18T10:39:56.000Z
Section: Regulation

> Fees or tips appeared on 96% of loans in a direct-to-consumer sample covering September 2024 through August 2025.

Direct-to-consumer paycheck-advance apps carried an average $207.85 in annual fees and tips per borrower, while fees or tips appeared on 96% of loans in a U.S. transaction sample covering September 2024 through August 2025.

The average advance was $113.31 for nine days and cost $6.49 in fees. Annualizing the average advance’s nine-day cost produced an illustrative APR of 232%; it does not represent the amount borrowers paid in a year.

The national sample covered 9,987 borrowers, while a broader screen identified 346,902 app borrowers. The sample may not represent users across the market. Some advances or repayments routed through in-app wallets or accounts outside the observed bank data may also be missing.

Frequent borrowers accounted for most of the direct-to-consumer fees and tips: those taking 25 or more advances a year accounted for 82% of the charges. Across direct-to-consumer and employer-linked services, borrowers took an average of 33 advances a year, and 42% of advances were below $100.

Direct-to-consumer services estimate wages earned and typically collect repayment from a bank account. Employer-linked services use payroll information and generally collect repayment through payroll. Costs for the employer-linked services were not calculated because payroll deductions and related fees generally were not visible in the bank transactions.

A separate 2022 estimate put the number of workers using both types of service at roughly 10 million, with $31.9 billion in advances that year. That estimate covers both types and does not establish a current user count.

In December 2025, the Consumer Financial Protection Bureau (CFPB) withdrew a proposed interpretive rule from 2024 and issued an advisory opinion on qualifying earned-wage-access products. The opinion says products meeting its criteria are not credit under the Truth in Lending Act. It also says a bona fide voluntary tip is not a finance charge, while an effectively imposed fee may count. The opinion is guidance and has no force or effect of law outside the federal government.