Launched in 2017 as a personal finance assistant, in 2021 Dave went public through a $4 billion Spac deal and is now a financial platform offering a host of services to more than 10 million customers. The firm describes the customers it targets as being “financially vulnerable” or “financially coping". Among the services offered to these users is a cash advance feature that promised up to $500 "instantly". However, according to the FTC complaint, the full $500 was offered only a tiny percentage of the time while users had to pay an "express fee" if they wanted the money instantly rather than after two to three business days. In addition, the fee - between $3 and $25 - was not disclosed until after the sign up process was complete and users had provided access to their bank account. Dave, says the FTC, also often charged customers 15% of their advance as a "tip". This "tip" can be avoided but many users were unaware they were being charged it or that they can say no. According to one user cited by the FTC: “The interface is set up to trick you into giving the tip...I feel cheated/scammed by this whole process.” In addition, consumers are shown a screen featuring a cartoon of a small child surrounded by food, and the options for “10 Healthy Meals,” “15 Healthy Meals,” and “20 Healthy Meals,” suggesting that tip will see Dave provide food to people in need.

The FTC argues that the interface leads people to believe that, for every percentage of tip they are giving, Dave is donating an actual healthy meal to a needy child. But, according to the complaint, Dave donates just 10 cents for each percentage in “tip” the consumer clicks on and keeps the rest. If users discover they can leave a lower tip and attempt to do so, they see food taken away from a cartoon child until the image of the child is finally replaced by an image of an empty plate. According to SEC filings, Dave made $149 million in revenue from these so-called “tips” from 2022 through the first six months of 2024. “Dave lured in consumers living paycheck-to-paycheck with false claims of big-dollar advances, then reached into their pockets to give itself a so-called ‘tip,’” says Samuel Levine, director, FTC Bureau of Consumer Protection. In a statement, Dave says: "The FTC asserts many incorrect claims regarding Dave’s disclosures and how the Company acquires consent for the fees associated with our products. "For the avoidance of doubt, Dave’s ability to charge subscription fees and optional tips and express fees is not in question. We believe this case is another example of regulatory overreach by the FTC, and we intend to vigorously defend ourselves."