Terms Unconditional

Payday & Small-Dollar Lenders · Fintech (cash advance / membership installment loans) · Regulatory action + Private litigation

MoneyLion (ML Plus / MoneyLion Technologies; Gen Digital subsidiary)

Headline

MoneyLion settled the CFPB's Military Lending Act suit in November 2025 for $1.75 million in restitution and no civil penalty, without admitting wrongdoing - and the deal let it keep leaving $19.99-$29/month…

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

MoneyLion settled the CFPB's Military Lending Act suit in November 2025 for $1.75 million in restitution and no civil penalty, without admitting wrongdoing - and the deal let it keep leaving $19.99-$29/month 'membership' fees out of the 36% military rate cap if disclosed and cancellable after two months. The harder exposure is now at the state and local level: the New York Attorney General (usury and fraud, filed April 2025), the City of Baltimore, and a Pennsylvania county prosecutor have all sued over its 'Instacash' advances, and two private MLA/TILA class actions survived motions to dismiss and to compel arbitration (on appeal to the Second Circuit). Gen Digital (Norton/Avast/LifeLock parent) bought MoneyLion in April 2025 for about $1 billion.

  • SeveritySeverity 4 of 5, not independently verified. MoneyLion settled the CFPB's Military Lending Act suit in November 2025 for $1.75 million in restitution and no civil penalty, without admitting wrongdoing - and the deal let it keep leaving $19.99-$29/month…
  • Evidence tierUnassigned
  • Claims confirmedNo sourced claims yet
  • Last verified2026-10-16

Primary source. www.hinshawlaw.com/en/insights/blogs/consumer-crossroads-where-financial-services-and-litigation-intersect/lenders-should-approach-the-recent-cfpbmoneylion-military-lending-act-settlement-with-caution — 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 - Terms (updated June 2026) incorporate a separate Agreement for Resolving Disputes: individual arbitration administered by National Arbitration and Mediation (NAM), class-action waiver ('ONLY INDIVIDUAL RELIEF IS AVAILABLE'), small-claims carve-out, and a mass-arbitration protocol for 25+ coordinated claimants (10+10 bellwethers, global mediation, then batches of 100); if a court strikes the mass-arbitration section, the whole arbitration agreement is void. Note: two S.D.N.Y. courts denied MoneyLion's motions to compel arbitration in MLA cases (MLA bars arbitration for covered borrowers); on appeal.

30-day opt-out window from sign-up.30-day window from sign-upday 0day 30
Opt-out window: 30 days. 30-day opt-out window from sign-up. Recorded as: 30 days from first agreeing; signed written notice by mail to MoneyLion Legal Department, 60 Rio Salado Pkwy #1000, Tempe, AZ 85281, or email to arbitration@moneylion.com.

Data sharing

Privacy policy (updated June 2026) says MoneyLion does not 'sell' but does 'share' personal information as defined under California law (cross-context behavioral advertising via cookies/pixels; lookalike audiences with Facebook and Taboola). Linked bank-account data (balances, activity, direct-deposit and spending data) may be shared 'with our affiliates and marketplace partners to better personalize your offers' where permissions exist. Precise location for its Driver Score feature is collected by an auto-insurance partner (Zendrive). Affiliate marketing is disclosed; the policy does not name Gen Digital. GLBA-covered data sits under a separate Financial Privacy Notice (not reviewed this pass). Now that MoneyLion sits inside a consumer-security conglomerate, cross-use of financial-distress data with Gen's identity/antivirus customer base is a structural question to watch (tracker inference). No MoneyLion data breach located this pass.

Who holds your data. Data chain: MoneyLion (ML Plus / MoneyLion Technologies; Gen Digital subsidiary), then Gen Digital Inc. (NASDAQ: GEN) - acquisition closed April 17, 2025 (~$1B; $82/share cash plus a $23 CVR) (parent).

Fees and billing

CFPB alleged $19.99-$29/month membership fees on 'Credit Builder Plus' loans pushed servicemember APRs above the MLA 36% cap and that members could not cancel until loans were repaid; settlement now bars conditioning cancellation on payoff beyond up to two initial months and bars negative credit reporting of unpaid membership fees. The NY AG alleges Instacash advances are 'illegal, high-interest loans' (usury, fraud, GBL 349/350). Allegations only; MoneyLion denies liability.

Contacts

Privacy contact. Data Rights Request Form at moneylion.com/privacy-notice/ccpa/; 1-888-704-6970 (rights requests); 1-844-224-0087 (privacy questions)

Legal notice. MoneyLion Legal, 60 E Rio Salado Pkwy #1000, Tempe, AZ 85281 (Terms and Privacy Policy, June 2026). Privacy rights requests may also be mailed to Legal Department, 249 West 17th Street, 4th Floor, New York, NY 10011. Corporate HQ not separately verified this pass.

Mailing address. Not recorded.

Written channel present
Paper trail: written. Written channel present.

Evidence

No claims have been itemized for this row yet.

Sources

SourceClaimTierStatusQuote
Law firm analysis (secondary) · 2025-12-22
www.hinshawlaw.com/en/insights/blogs/consumer-crossroads-where-financial-services-and-litigation-intersect/lenders-should-approach-the-recent-cfpbmoneylion-military-lending-act-settlement-with-caution
whole rowUnassignedconfirmed“without any admission of wrongdoing by the company”
Quote basis: not recorded.
News (Banking Dive via Yahoo Finance) · 2025-11-25
finance.yahoo.com/news/moneylion-pay-1-75m-settle-120218437.html
whole rowUnassignedconfirmed“illegal, high-interest loans”
Quote basis: not recorded.
Consumer advocacy blog (opinion) · 2025-12-12
consumerfed.org/news/blogs/trump-s-cfpb-waves-the-white-flag-on-the-military-lending-act-to-give-moneylion-a-sweetheart-deal-why/
whole rowUnassignedconfirmed“allows MoneyLion to continue to exclude the fees from the MAPR”
Quote basis: not recorded.
Company press release (primary) · 2025-04-17
newsroom.gendigital.com/2025-04-17-Gen-Completes-Acquisition-of-MoneyLion,-Accelerating-the-Companys-Leadership-in-Financial-Wellness
whole rowUnassignedconfirmed“We're thrilled to welcome MoneyLion to the Gen family.”
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 to 2nd Circuit”
Quote basis: not recorded.
Company terms (primary) · 2026-06
www.moneylion.com/terms-and-conditions/
whole rowUnassignedconfirmed“any arbitration shall be conducted by NAM (National Arbitration and Mediation)”
Quote basis: not recorded.
Company arbitration agreement (primary) · 2026-06
network.moneylion.com/legal-arbitration/
whole rowUnassignedconfirmed“You may opt out of arbitration within 30 days of first agreeing to this Agreement”
Quote basis: not recorded.
Company privacy policy (primary) · 2026-06
www.moneylion.com/privacy-notice/
whole rowUnassignedconfirmed“We do not sell your Personal Information, but we do “share” your Personal Information as defined under California law.”
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
https://www.moneylion.com/privacy-notice/
Not fetched yetNOT CONFIRMED
Terms of service
https://www.moneylion.com/terms-and-conditions/
Not fetched yetNOT CONFIRMED
Website
https://www.moneylion.com
Not fetched yet—
Primary source
https://www.hinshawlaw.com/en/insights/blogs/consumer-crossroads-where-financial-services-and-litigation-intersect/lenders-should-approach-the-recent-cfpbmoneylion-military-lending-act-settlement-with-caution
Verification: Unverified - heuristic first draft
Not fetched yet—

Enforcement

ActionAmountLink
CFPB v. MoneyLion Technologies Inc., ML Plus, LLC, et al.
Consumer Financial Protection Bureau, 2025
No. 1:22-cv-08308 (S.D.N.Y. filed Sept. 29, 2022); stipulated final judgment entered Nov. 24, 2025.
$1.8Mproposed

Links are proposed matches, not yet reviewed.

State statute

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