True Cost of Borrowing

For a payday or title loan, an APR is usually disclosed by law. For a pay-in-4 buy now pay later plan (four payments, no interest), for most cash advance apps, and for standard overdraft coverage on a checking account, no APR has to be disclosed — these fall outside the federal truth-in-lending rules that require one. (Longer interest-bearing installment plans from the same BNPL brands, and formal overdraft lines of credit, do disclose an APR.) The 'effective APR' shown here is our own annualized estimate of what the fee actually costs you, using the same simple-interest annualization the CFPB used in its own overdraft and paycheck-advance research. It is not an APR your provider disclosed — for these products, none is.

Not reliably. The CFPB issued a rule in 2024 saying BNPL should carry the same billing-dispute rights as a credit card, but it withdrew that rule on May 12, 2025, and has said it will not reissue it — though that's an agency policy position, not a change in the underlying statute, so it's worth re-checking. Some providers voluntarily offer dispute rights in their terms — that's a contractual promise, not a legal guarantee. If you paid through a credit card or debit card network, you may still have chargeback rights through that card, separate from BNPL regulation.

No. Congress voted to nullify that rule under the Congressional Review Act, and the resolution was signed on May 9, 2025 — the rule never took effect. Under the CRA, federal agencies also can't issue a substantially similar rule without new legislation from Congress, so this isn't a rule that's coming later or paused; banks currently set their own overdraft fees.

Federally, the CFPB's most recent position — an advisory opinion issued December 23, 2025 — holds that covered earned wage access products are not credit under federal truth-in-lending law, so no APR disclosure is required. States are more of a patchwork: 12 states had earned-wage-access laws as of March 2026, and more have considered their own since — check your state. All 12 bar late fees and limit collection against you; most also require a free, non-expedited option. California is the exception — its financial regulator treats non-employer income-based advances as loans under state law as of February 2025.

There's no current authoritative national average — it varies by bank. $35 is the most common fee at large banks, and about 68% of very large financial institutions charge somewhere between $30 and $37. Some banks have dropped the fee to $10 or eliminated it entirely. Check your bank's specific fee schedule, and if it's high, that's a real reason to consider switching to a Bank On certified account, which doesn't charge overdraft or NSF fees — that's part of what certification requires.

It depends on what the money is for, which is why this tool asks. Worth checking before you borrow again: a credit union Payday Alternative Loan (capped at 28% APR, though a permitted $20 application fee can add to that), asking your employer's payroll department for an advance or hardship fund (often free), and — if the money is for rent, utilities, food, or a medical bill — assistance programs that don't have to be paid back at all. This tool shows options matched to your situation on every results page, even when the cost comes out to $0.

No. Worker's AdvoKit is a free educational tool, not a law firm, financial advisor, or tax professional, and using it doesn't create any professional relationship. The 'effective APR' figures are our own estimates based on what you enter — not figures your provider disclosed. Fees, state laws, and federal rules in this area change quickly. Verify anything that matters with your own agreement, your state's regulator, or a qualified professional before you act on it.