Consumer complaint received 2026-04-27 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Earned wage access
Issue: Confusing or missing disclosures — 
Company: Activehours
State: MD

Complaint narrative:
This complaint is filed as a supplement to complaint number XXXX, filed XX/XX/year>, and should be reviewed in conjunction with that record and the two supplemental complaints filed this morning. This filing addresses a single specific claim made by EarnIn in their formal response to complaint number XXXX, submitted to this federal body on XX/XX/year>. That claim is that this matter was reviewed thoroughly at the highest levels within EarnIn before their response was filed. That claim was misrepresented and should be addressed. The Claim In their XX/XX/year> federal response EarnIn stated explicitly that this matter had been escalated to the highest levels within the company to ensure a comprehensive review. That statement was not a casual representation. It was submitted formally to a federal regulator as the foundation of their resolution offer and their request that this matter be considered finally resolved. The CFPB is asked to examine whether that characterization is accurate in light of what EarnIn did on the same day they made it. What A Thorough Review At The Highest Levels Would Have Captured A thorough review conducted at the highest levels of EarnIn prior to filing their XX/XX/XXXX federal response would have captured the following. Each item was documented, active, and accessible within EarnIns own systems and correspondence channels before that filing was made. One Three direct questions submitted to EarnIns VP of Customer Care between XX/XX/XXXX at XXXX XXXX and XX/XX/XXXX at XXXX XXXX within her own invitation window. Not one was answered. Not one was referenced in EarnIns federal response. Two A formal enrollment misrepresentation complaint submitted directly through EarnIns official complaint channels on XX/XX/XXXX at XXXX XXXX fourteen hours before the federal filing. Not acknowledged. Not incorporated. No response to date. Three Explicit written warnings delivered to EarnIns executive and legal leadership on XX/XX/XXXX at XXXX XXXX and XX/XX/XXXX at XXXX XXXX and XXXX XXXX stating that public documentation of this matter was forthcoming and would be directed at EarnIns target audience. Those warnings were delivered through the same correspondence channel that EarnIns General Counsel and Chief Compliance Officer confirmed receiving. They were explicit. They were timestamped. They named EarnIns target audience specifically. Four A public social media post published on approximately XX/XX/year> three days before EarnIns federal filing in r/cashadvanceapps, a community EarnIns verified account was actively engaged in, containing the exact chat log that had been in front of EarnIns support structure, supervisors, quality assurance team, VP of Customer Care , General Counsel, and Chief Compliance Officer since XX/XX/XXXX. That post had accumulated over XXXX views by the time EarnIn filed their federal response. Five The complete email correspondence chain between XX/XX/XXXX and XX/XX/year> containing additional admissions, failed remediation attempts, and executive level acknowledgments that developed after the original complaint was filed and were not referenced in EarnIns federal response. A thorough review conducted at the highest levels of this company would have identified every one of these items before a federal response was filed. None were addressed. None were incorporated. None were acknowledged. The Question EarnIn Can not Answer EarnIn is not a passive organization with a generic public presence. They are an active and deliberate participant in the exact financial communities where their target consumers live. Their verified XXXX account was engaged across multiple financial subreddits on XX/XX/XXXX the same day they filed their federal resolution. XXXX. XXXX. XXXX. XXXX. These are not incidental communities. These are the precise communities where EarnIns core consumer base discusses the exact products at the center of this matter. They were not browsing. They were operating. Dispensing financial guidance. Building brand trust. Positioning themselves as the informed and benevolent authority in the consumer finance space. On that same day a post titled EarnIn failed to provide proper disclosures at the time of account cancellation, later acknowledged material harm sat in r/cashadvanceapps with over XXXX views. It contained the exact chat log that had been circulating internally for nine days. It had been live for three days. It was published after three explicit written warnings of forthcoming public documentation had been delivered to EarnIns executive and legal leadership through correspondence they confirmed receiving. Between one and two hours after filing their federal resolution EarnIns verified account responded to that post as though encountering this situation for the first time. On the evening of XX/XX/XXXX at XXXX XXXX that question was posed directly to EarnIns verified XXXX account through a private message. It received no response. It is now posed formally to this federal body. How did EarnIn miss this? This is not a rhetorical question. It is a structural one that EarnIns own thorough review claim can not survive. EarnIn presents itself publicly as an omniscient and trustworthy authority in the consumer finance space. Their entire product depends on that omniscience they monitor paycheck deposits to the dollar, track direct deposit timing in real time, and position themselves as the informed alternative to predatory financial institutions. They can not simultaneously claim to know exactly when a paycheck posts to a consumers account and claim they missed a XXXX view post about their own product failure sitting in a fintech subreddit they were actively engaged in on the same afternoon they filed a federal resolution. If this matter was genuinely reviewed thoroughly at the highest levels by a General Counsel who confirmed receipt, a Chief Compliance Officer who was copied throughout, a VP of Customer Care who was in direct correspondence, and ten representatives who engaged across nine days how did not one person in that review share three explicit written warnings of forthcoming public documentation with the team managing EarnIns public presence in the exact community where that documentation appeared three days before their filing? The warnings were in the record. The record was reviewed. The public team was active in that community. The post was three days old when they commented on it as though seeing it for the first time. The Two Explanations There are only two explanations for EarnIns public response to that post and EarnIn must answer for both of them before this federal body. The first explanation is that EarnIns internal communication is so completely fractured that a public post containing an active federal complaint involving their own General Counsel published three days before their filing, preceded by three explicit written warnings delivered four to five days before their filing, accumulating over XXXX views in a community their own verified account was actively engaged in never reached the people conducting the review they characterized as thorough and comprehensive. If that is the case then the claim o f thorough review at the highest levels made formally to this federal body is not accurate. It is a misrepresentation of EarnIns actual internal process submitted to a federal regulator as the basis for closing a consumer complaint. The second explanation is that EarnIns internal communication did function. That the post was known. That the warnings were known. And that their publi c team was directed to engage with that post as though encountering it for the first time as a deliberate strategy to move a XXXX view public thread into a private channel where it disappears from the record while simultaneously filing a federal resolution characterizing the same matter as closed. If that is the case then EarnIns public response was coordinated and performative and their characterization of their internal process as thorough is a calculated misrepresentation submitted to this federal body to manufacture the appearance of comprehensive engagement where none existed. Neither explanation is consistent with a thorough review conducted at the highest levels of the company. Both are inconsistent with the representations made formally to this federal body on XX/XX/year>. One represents institutional incompetence of a scale that directly contradicts EarnIns own characterization of their review process. The other represents deliberate misrepresentation to a federal regulator. EarnIn must answer before this federal body which of those two explanations is true. Their filing claims the former is impossible. Their conduct confirms one of them is not. The Standard EarnIn Set For Themselves EarnIn did not describe their review as adequate. They did not describe it as reasonable. They described it as thorough. They described it as conducted at the highest levels. They submitted that characterization formally to a federal regulator as the foundation of their request that this matter be considered closed. The evidence presented in this filing produced entirely by EarnIns own conduct on the same day that characterization was made demonstrates that the review was not thorough. It was not comprehensive. And the claim that it was constitutes a material misrepresentation made to this federal body in a formal regulatory response. The CFPB is respectfully requested to examine that claim and to require EarnIn to account for the specific failures of internal communication and review documented here before this matter is permitted to remain closed. Please note : the points raised in this filing are not simply my interpretation of the events of XX/XX/year>. They are points that emerged directly through EarnIns own conflict resolution process acknowledged, confirmed, and in several instances formally admitted by EarnIns own representatives, supervisors, and executive leadership across an entirely written correspondence record spanning nine days. They are brought to the attention of this federal body because internal dialogue despite being initiated, documented, and pursued in good faith at every stage was effectively abandoned on multiple occasions by EarnIn across that same record. EarnIn will now demonstrate through their response to this federal body either a contrasting or a comparable approach to the pattern documented here, with whatever urgency they deem this matter deserves.

Company response to consumer: Closed with explanation