Other companies market advance pay directly to the consumer, called “direct-to-consumer advance”. In this model consumers represent their earned wages (such as through geolocation data or based on direct deposit history), seek an advance payment, and their bank account is debited on their self-reported payday. This is considered Direct to Consumer Advance Pay and comes with risks of overextending consumers across multiple platforms and incurring overdraft fees. Employees would be better served asking their employer to offer an Earned Wage Access program benefit.

As more “advance pay” related business models emerge, regulators at the state and federal levels are taking a closer look at regulations in these areas to ensure consumers are protected.