The fintech industry’s maneuvering could circumvent strong state-level protections for interest on consumer loans. For example, Vermont caps single-loan interest rates at 18 percent. Monica Burks from the Center for Responsible Lending testified before lawmakers over a bill that would carve out EWA products from the 18 percent limit. Referring to EarnIn’s tipping model and expedited service fees, she said, “This is actually strong evidence that their business model depends on loans for which the true cost is often going to be higher than advertised or disclosed, with an APR that would well exceed Vermont’s usury cap.”