Terms Unconditional

Payday & Small-Dollar Lenders · Fintech (AI chatbot budgeting / cash advance) · Regulatory action + Private litigation

Cleo AI (Cleo AI, Inc.)

Headline

Cleo AI agreed in March 2025 to pay $17 million in refunds to settle FTC charges that its chatbot app advertised hundreds of dollars in cash advances that 'almost no one' received, charged extra for 'same-day' money…

Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.

Cleo AI agreed in March 2025 to pay $17 million in refunds to settle FTC charges that its chatbot app advertised hundreds of dollars in cash advances that 'almost no one' received, charged extra for 'same-day' money that could still arrive the next day, and kept billing subscribers who asked to cancel (settlement, not a liability finding). Private plaintiffs allege Cleo's $3.99 'Express Fee' plus $5.99-$14.99 monthly subscription produce APRs as high as 986% on advances marketed at zero interest; an MLA/TILA class action survived dismissal in Washington federal court (appeal stayed), and in May 2026 a Pennsylvania federal judge sent two plaintiffs to arbitration but let a third proceed because he never assented to the terms.

  • SeveritySeverity 4 of 5, not independently verified. Cleo AI agreed in March 2025 to pay $17 million in refunds to settle FTC charges that its chatbot app advertised hundreds of dollars in cash advances that 'almost no one' received, charged extra for 'same-day' money…
  • Evidence tierUnassigned
  • Claims confirmedNo sourced claims yet
  • Last verified2026-10-16

Primary source. www.ftc.gov/news-events/news/press-releases/2025/03/cash-advance-company-cleo-ai-agrees-pay-17-million-result-ftc-lawsuit-charging-it-deceives-consumers — Unverified - heuristic first draft.

Last verified 23 days agoverified 23 days ago0180 days
Freshness. Last verified 23 days ago (2026-10-16); stale after 180 days.

Terms

Arbitration

Yes per court record - the M.D. Pa. described Cleo's and Synapse's terms as requiring binding arbitration and waiving class/representative proceedings, and enforced them against plaintiffs who clicked through updated T&Cs in 2025; current live terms not retrieved this pass.

60-day opt-out window from sign-up.60-day window from sign-upday 0day 60
Opt-out window: 60 days. 60-day opt-out window from sign-up. Recorded as: 60 days by email after clicking 'I agree' (as described by the M.D. Pa. in Hoover, May 29, 2026); current terms not independently verified.

Data sharing

Cleo's US privacy policy could not be retrieved this pass (site blocked automated access) - not verified. Structural note: Cleo is an AI chatbot that reads users' linked bank-transaction data to give spending advice, and the Hoover court record shows it relied on Synapse Financial Technologies (with Evolve Bank & Trust) as banking middleware - the same intermediary chain implicated in the 2024 Synapse collapse (tracker inference; Synapse's collapse not re-verified here). No Cleo breach located this pass.

Fees and billing

FTC alleged: advertised advance amounts almost never available; extra fee for promised same-day/instant advances that could still take until next day; recurring subscription charges after cancellation requests; cancellation refused while advances outstanding. Hoover plaintiffs allege $5.99-$14.99/month subscription plus $3.99 Express Fee and undisclosed APRs up to 986% (allegations, M.D. Pa. Doc. 20 as summarized by the court).

Contacts

Privacy contact. Not recorded.

Legal notice. Not verified this pass. The Hoover court summarized the plaintiffs' complaint as describing Cleo as 'a New York based technology company' (allegation, not verified); check New York / Delaware entity records for Cleo AI, Inc.'s registered agent.

Mailing address. Not recorded.

No published channel
Paper trail: none. No published channel.

Evidence

No claims have been itemized for this row yet.

Sources

SourceClaimTierStatusQuote
FTC press release (primary) · 2025-03-27
www.ftc.gov/news-events/news/press-releases/2025/03/cash-advance-company-cleo-ai-agrees-pay-17-million-result-ftc-lawsuit-charging-it-deceives-consumers
whole rowUnassignedconfirmed“almost no one received anything close to the advertised amounts”
Quote basis: not recorded.
Court memorandum (primary) · 2026-05-29
newmedialaw.proskauer.com/wp-content/uploads/sites/49/2026/06/HooverVCLeoAI-5-29-26-Order.pdf
whole rowUnassignedconfirmed“annual percentage rates (“APRs”) which can reach up to 986%”
Quote basis: not recorded.
Advocacy-group litigation tracker (secondary) · 2026-09-29
www.responsiblelending.org/research-publication/payday-loan-app-litigation-tracker
whole rowUnassignedconfirmed“Motion to Dismiss Denied; Appealed 9th Circuit; stayed”
Quote basis: not recorded.
Law firm analysis (secondary) · 2026-01-05
www.dwt.com/blogs/financial-services-law-advisor/2026/01/cfpb-revisits-2020-opinion-earned-wage-access
whole rowUnassignedconfirmed“formally withdraws the CFPB's 2024 proposed interpretive rule”
Quote basis: not recorded.
Law firm client alert (secondary) · 2025-06-10
www.mcguirewoods.com/client-resources/alerts/2025/6/connecticut-and-louisiana-poised-to-enact-earned-wage-access-legislation-marking-significant-policy-shift-among-states/
whole rowUnassignedconfirmed“SB 1396 caps the total finance charge for EWA at $4 per advance or $30 per month”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
No URL recorded
Not fetched yetNOT CONFIRMED
Terms of service
https://web.meetcleo.com/page/term-conditions
Not fetched yetNOT CONFIRMED
Website
https://www.meetcleo.com
Not fetched yet—
Primary source
https://www.ftc.gov/news-events/news/press-releases/2025/03/cash-advance-company-cleo-ai-agrees-pay-17-million-result-ftc-lawsuit-charging-it-deceives-consumers
Verification: Unverified - heuristic first draft
Not fetched yet—

Enforcement

ActionAmountLink
FTC v. Cleo AI, Inc.
Federal Trade Commission, 2025
FTC v. Cleo AI, Inc. (S.D.N.Y. filed Mar. 27, 2025) (civil action number not verified this pass).
$17Mproposed

Links are proposed matches, not yet reviewed.

State statute

No HQ state on file, so no state statute applies by headquarters.