Cash advance app rules in Connecticut

Fees

• For an "earned but unpaid wage or salary income advance", a small loan may not carry a total finance charge that exceeds "(i) four dollars per advance, or (ii) thirty dollars per month" (C.G.S. 36a-558(d), as amended by PA 25-155).
• "Finance charge" includes "any fee, voluntarily or otherwise, charged, agreed to or paid" in connection with a small loan (PA 25-155, Sec. 1).
• The provider must offer at least one option per transaction to receive the advance at no cost, and clearly disclose how to choose it (PA 25-155, Sec. 3(a)(1)).
• A provider that charges a finance charge must offer either an advance of at least 75% of earned but unpaid income for the pay period, or no more than one advance per pay period (PA 25-155, Sec. 3(a)(2)(A)).
• The advance must be less than $750 and no more than the earned but unpaid income for the pay period (PA 25-155, Sec. 1).

Tips

• Each time it asks for a voluntary charge, the provider must disclose that the charge is voluntary, that the borrower may choose $0, and that advance amounts and frequency do not depend on it (Sec. 3(a)(2)(B)).
• The provider may not set a voluntary charge above $0 as the default, or ask for one before telling the borrower how much they are approved for (Sec. 3(b)(2), (3)).
• The provider may not share any finance charge with the employer (Sec. 3(b)(4)).

Other rules

• Repayment must be a single payment on the next payday, no more than 34 days after the advance. If it fails, the provider may reschedule into no more than three installments (Sec. 3(a)(4)).
• The provider must verify income using payroll data or another approved method, and have the borrower attest that they are not taking advances from more than one provider on the same wages (Sec. 3(a)(3)).
• No requesting repayment before the next payday; no credit card payments; no late fees, deferral fees or interest (Sec. 3(b)(5)-(7)).
• No unsolicited outbound calls, lawsuits, third-party collection or sale to a collection agency to collect (Sec. 3(b)(8)).
• No use of credit reports or scores; no reporting non-payment to credit bureaus or collection agencies (Sec. 3(b)(9), (10)).
• The provider must reimburse overdraft or NSF fees caused by early or wrong-amount debits (Sec. 3(a)(5)).
• In 2023 guidance on PA 23-126, the Department said EWA advances are generally "small loans" when the APR, including tips, is over 12% (effective Oct. 1, 2023).

Who is licensed or registered

The state publishes an official list.

We have not been able to check this list yet (it sits behind a verification step we don’t automate). Search it yourself at the link above.

Lists change. Check the regulator’s current list before you rely on it.

Enforcement and official actions

• 2023-09-11 Connecticut Department of Banking, guidance. Industry guidance on Public Act 23-126 said EWA products are generally covered by the Small Loan Lending and Related Activities Act when the amount is $50,000 or less and the APR, including tips, exceeds 12%. Official document

A complaint or lawsuit contains allegations; it is not a finding unless a court or agency says so.

What we could not confirm

• Which apps hold a Connecticut small loan license: NMLS Consumer Access was not queried because it requires a CAPTCHA.
• Any Department of Banking guidance issued after PA 25-155 was not searched for.