Payday & Small-Dollar Lenders · Neobank (small-dollar line of credit) · No confirmed finding (unverified, not clean)
Varo Bank (Varo Bank, N.A. - Varo Advance)
Headline
Nothing confirmed
Varo is the only company on this tab that is itself a nationally chartered bank, so its small-dollar 'Varo Advance' runs under federal bank rules rather than state payday or EWA licensing.
Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.
What this pass recorded. Varo is the only company on this tab that is itself a nationally chartered bank, so its small-dollar 'Varo Advance' runs under federal bank rules rather than state payday or EWA licensing. The October 2026 agreement prices advances as flat fees with a 0% stated APR - $8 on a $100 advance for customers with $800+ in monthly deposits, $20 for those without - repaid in 15 to 30 days; by the tracker's own math that $20 fee is about 243% annualized at 30 days and about 487% at 15 days, and the higher price falls on customers with less money coming in. No regulator action, breach or class action was located this pass.
- Severity
- Evidence tierUnassigned
- Claims confirmed
- Last verified2026-10-16
Primary source. prod-cdn.varomoney.com/agreements/ADVANCE_AGREEMENT.pdf — Unverified - heuristic first draft.
Terms
Arbitration
Yes - General Terms Agreement (eff. May 4, 2026): binding individual AAA arbitration after a 30-day informal claim-notice period; class and consolidated claims barred; small-claims option (removable to arbitration if appealed).
Data sharing
Online Services Privacy Policy (eff. Oct. 6, 2026) collects device and mobile advertising IDs (IDFA/GAID), online activity and general location, and biometric data used 'strictly' for identity verification and fraud (not sold); shares aggregated/de-identified data 'with third parties for any purpose'. CCPA Notice (eff. Oct. 1, 2020 - six years old) says Varo does not 'sell' personal information and lists business-purpose disclosures only. GLBA consumer privacy notice not reviewed this pass. No breach located.
Fees and billing
Varo Advance flat fees ($1.60-$80 depending on amount and deposit tier; e.g., $100 advance = $8 with $800+ deposits, $20 without); 0.00% APR stated for interest; repayment 15-30 days, automatic. Tracker-calculated annualized cost of a $20 fee on $100: ~243% at 30 days, ~487% at 15 days (illustrative, not from any filing).
Contacts
Privacy contact. Not captured this pass; disputes line 1-877-377-8276 (General Terms)
Legal notice. Varo Bank, N.A., ATTN: Legal Department, PO Box 108, Draper, UT 84020 (General Terms claim-notice and arbitration opt-out address). Corporate HQ not verified this pass.
Mailing address. Not recorded.
Evidence
No claims have been itemized for this row yet.
Sources
| Source | Claim | Tier | Status | Quote |
|---|---|---|---|---|
| Bank agreement (primary) · 2026-10-06 prod-cdn.varomoney.com/agreements/ADVANCE_AGREEMENT.pdf | whole row | Unassigned | confirmed | “You must select an available repayment date between 15 to 30 days from the date you get the Advance.” Quote basis: not recorded. |
| Bank agreement (primary) · 2026-05-04 prod-cdn.varomoney.com/agreements/GENERAL_TERMS_AGREEMENT.pdf | whole row | Unassigned | confirmed | “You may opt out of this Arbitration Clause for all purposes by mailing a written arbitration opt out notice to ATTN: Legal Department, PO Box 108, Draper, UT 84020 via Certified U.S. Mail, Return Receipt Requested.” Quote basis: not recorded. |
| Bank privacy policy (primary) · 2026-10-06 prod-cdn.varomoney.com/agreements/ONLINE_AND_MOBILE_PRIVACY_POLICY.pdf | whole row | Unassigned | confirmed | “Varo does not sell, lease, trade, or otherwise profit from your biometric data.” Quote basis: not recorded. |
| Bank CCPA notice (primary) · 2020-10-01 prod-cdn.varomoney.com/agreements/CCPA_NOTICE.pdf | whole row | Unassigned | confirmed | “We do not “sell” Personal Information subject to the CCPA” Quote basis: not recorded. |
| Advocacy-group litigation tracker (secondary) · 2026-09-29 www.responsiblelending.org/research-publication/payday-loan-app-litigation-tracker | whole row | Unassigned | confirmed | No quote recorded. 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 row | Unassigned | confirmed | “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 row | Unassigned | confirmed | “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
| Document | Last fetch | |
|---|---|---|
| Privacy policy https://prod-cdn.varomoney.com/agreements/ONLINE_AND_MOBILE_PRIVACY_POLICY.pdf | Not fetched yet | NOT CONFIRMED |
| Terms of service https://prod-cdn.varomoney.com/agreements/GENERAL_TERMS_AGREEMENT.pdf | Not fetched yet | NOT CONFIRMED |
| Website https://www.varomoney.com | Not fetched yet | — |
| Primary source https://prod-cdn.varomoney.com/agreements/ADVANCE_AGREEMENT.pdf Verification: Unverified - heuristic first draft | Not fetched yet | — |
Enforcement
No enforcement actions are linked to this row.
State statute
No HQ state on file, so no state statute applies by headquarters.