Underwriting is the product: a proprietary cash-flow model (CashAI) sets every ExtraCash limit without a credit score, a vendor-built chatbot (DaveGPT) absorbs support, and a federal lawsuit over fee disclosure runs alongside.
How is Dave using AI?
Dave's AI strategy is its underwriting engine, CashAI, which sets ExtraCash advances of up to $500 from real-time bank-account cash flow rather than credit scores; Dave says it has learned from more than 180 million originations. CashAI v5.5 went live in September 2025 and v6, with over 700 features, began rolling out in mid-2026. DaveGPT, a generative assistant built with Aisera, resolved up to 89% of inquiries at launch. Q2 2026 revenue was $170.8 million with 3.08 million monthly transacting members; a 2024 DOJ/FTC fee-disclosure lawsuit is still pending.
Category
Neobank
Founded
2015
Headquarters
Los Angeles, United States
Licence and supervision
Not a bank. Deposit accounts, debit cards and the ExtraCash overdraft product are issued by partner banks Evolve Bank & Trust and Coastal Community Bank (both FDIC members); Dave itself is a non-bank consumer financial services company subject to the FTC and CFPB, and since June 2026 funds ExtraCash receivables through Coastal.
Scale
3.08 million monthly transacting members and $170.8 million of revenue in Q2 2026 (quarter to June 30, 2026)
Flagship platform
CashAI
AI leadership
Jason Wilk · Gopi Kuchimanchi · Kyle Beilman
- CashAI, Dave's proprietary cash-flow underwriting engine, makes fully automated real-time credit decisions on ExtraCash with no credit check and no FICO or bureau data; the FY2025 10-K says it has drawn on more than 180 million ExtraCash originations and that Dave has advanced over $22 billion to members since inception.
- CashAI v5.5 was fully implemented in September 2025, trained on more than 7 million recent, fully matured ExtraCash originations and nearly doubling the feature set; Dave said early results showed higher average approval amounts, stronger conversion and lower delinquency than in Q2 2025.
- CashAI v6, built on more than 700 model features, nearly 400 of them new, began rolling out in Q2 2026 and had reached about a third of users by the August 2026 earnings call; management said it is designed to expand gross profit dollars within a controlled loss range rather than to minimise losses.
- DaveGPT, a generative AI customer-service assistant built on Aisera's platform, launched in January 2024 for Dave's 9.9 million members and, Aisera said, resolved upwards of 89% of member inquiries; the 10-K lists it alongside AI-powered fraud detection and income and expense prediction.
- The FTC sued Dave in November 2024 over advertising of up to $500 advances, undisclosed instant-transfer fees and 'tips'; the Justice Department filed an amended complaint on December 30, 2024 naming CEO Jason Wilk and seeking civil penalties. Dave moved all members to a flat 5% fee (minimum $5, cap $15) by February 2025 and says it continues to defend the case.
- Q2 2026: revenue $170.8 million (up 30%), ExtraCash originations $2.3 billion (up 27%), 3.08 million monthly transacting members (up 17%), 28-day past-due rate 2.12%, adjusted EBITDA $75.5 million; full-year 2026 revenue guidance raised to $725-735 million.
- Since June 1, 2026 ExtraCash receivables are funded through Coastal Community Bank, a change Dave says will unlock more than $200 million of liquidity; the Dave Flex Card, a credit product underwritten by CashAI, is in test cohorts and is not expected to contribute meaningful revenue in 2026.
What is CashAI?
Dave's proprietary underwriting engine assesses credit risk in real time by analysing cash-flow data from a member's primary bank account, hundreds of data points covering income patterns, spending and transaction history, and makes instant decisions with no FICO score or credit-bureau data. The FY2025 10-K says it has drawn on more than 180 million ExtraCash originations and billions of bank transactions; v5.5 (September 2025) nearly doubled the feature set and v6 (rolling out from Q2 2026) is built on more than 700 model features, nearly 400 of them new.[1][5][3]
What has Dave done on AI, and when?
- Aug 12, 2026
Earnings call details CashAI v6[3]
Management said v6 is built on more than 700 model features, nearly 400 new, had reached about a third of users and was delivering higher credit limits; investment would be concentrated in product, marketing and 'embedding AI more deeply across the organization'. On the DOJ case: 'no updates'.
- Aug 5, 2026
Q2 2026 results and CashAI v6 rollout[2]
Revenue $170.8 million (up 30%), ExtraCash originations $2.3 billion, 3.08 million MTMs, 28-day past-due rate 2.12%; guidance raised. Adjusted metrics now exclude litigation expense for the FTC/DOJ matter.
- Jul 7, 2026
Gopi Kuchimanchi appointed Chief Technology Officer[11]
Kuchimanchi, at Dave since 2021 and VP of Technology from 2023, had led CashAI's development; he said AI is 'foundational to how we build, decide and operate'.
- Jun 9, 2026
ExtraCash funding moves to Coastal Community Bank[10]
Effective June 1, 2026 Dave began funding ExtraCash receivables through its program agreement with Coastal Community Bank, which it expects to lower its cost of capital and unlock over $200 million of liquidity; the same structure is planned for the Flex card.
- Mar 2, 2026
FY2025 results: revenue up 60% on CashAI v5.5[4][1]
Revenue of $554.2 million (up 60%), net income $195.9 million, 2.9 million monthly transacting members; Wilk credited CashAI v5.5 with a lower 28-day past-due rate while originations grew 50%. The 10-K filed the same day reports about 280 full-time employees.
- Sep 10, 2025
CashAI v5.5 fully implemented[5]
The new model nearly doubled CashAI's feature set, was trained on more than 7 million matured ExtraCash originations and was optimised for the new fee structure; Dave reported more accurate risk ranking, higher approval amounts and lower loss rates than in Q2 2025.
- Feb 20, 2025
Transition to a flat ExtraCash fee completes[9]
The optional 'tips' and instant-transfer fee model was replaced for all members with a 5% fee (minimum $5, cap $15) and no charge for instant transfer to Dave Checking.
- Dec 30, 2024
Justice Department files amended complaint naming the CEO[8][1]
The DOJ took over the case, adding Jason Wilk as a defendant and seeking consumer redress, civil penalties and a permanent injunction under the FTC Act and ROSCA; Dave said it was already moving new members to a fee structure without tips or express fees.
- Nov 5, 2024
FTC sues Dave over cash-advance marketing and fees[7][1]
The FTC's complaint in the Central District of California alleged Dave advertised advances of up to $500 that few users received, did not disclose an instant-transfer fee of up to $25 and a $1 monthly fee up front, and collected hard-to-avoid 'tips'. Dave said many of the claims were incorrect.
- Jan 16, 2024
DaveGPT launches with Aisera[6]
A generative AI assistant built on Aisera's platform for Dave's 9.9 million members, able to answer inquiries, set up direct deposits and resolve issues end to end; Aisera said it resolved upwards of 89% of member inquiries.
- Jan 5, 2022
Dave lists on NASDAQ through a SPAC merger[1]
Legacy Dave, incorporated in October 2015, completed its merger with VPC Impact Acquisition Holdings III and began trading as DAVE.
Where does Dave use AI today?
| System | What it does | Status | Use case |
|---|---|---|---|
| CashAI cash-flow underwriting[1][5][3] | Real-time, fully automated analysis of a member's bank-account cash flow sets the ExtraCash approval amount with no credit check; v5.5 live since September 2025, v6 rolling out from mid-2026. | In production | Credit scoring & underwriting |
| DaveGPT[6][1] | Generative AI support assistant built with Aisera that resolves member inquiries, sets up direct deposits and handles account management through natural-language conversation; the 10-K describes it as improving response times while reducing operating costs. | In production | Customer-facing chatbots |
| AI fraud mitigation[1] | An AI-powered system analyses behavioural patterns and transaction anomalies in real time and creates user-level controls to stop fraudulent activity before losses occur, per the 10-K. | In production | Fraud detection |
| Income and expense prediction[1] | Models forecast upcoming cash flows to feed CashAI decisions and the in-app budgeting features; ExtraCash settlement is scheduled from the forecasted next paycheck. | In production | Generative & agentic AI |
| Dave Flex Card underwriting[3][2] | A credit-based card with flexible repayment, underwritten by CashAI, in test cohorts starting with higher-credit-quality members; no meaningful 2026 revenue expected. | Pilot | Credit scoring & underwriting |
| Vendor-built generative AI[1][6] | The 10-K discloses that DaveGPT is offered through a third-party vendor (Aisera) and lists AI-related technical, legal and reputational risks among its risk factors. | In production | Third-party & vendor AI |
| AI across functions[3][11] | Management said in August 2026 that incremental investment would go to product, marketing and embedding AI more deeply across the organisation; the new CTO described AI as foundational to how Dave builds, decides and operates. | Rolling out | AI governance (general) |
Use-case links open the tracker's rules-by-use-case matrix: which documents govern each system type.
What has Dave disclosed in numbers?
| Metric | Value | As of |
|---|---|---|
| ExtraCash originations used to train CashAI | more than 180 million since inception; over $22 billion advanced[1] | Dec 31, 2025 |
| CashAI v6 model features | more than 700, nearly 400 of them new; deployed to about one-third of users[3] | Aug 12, 2026 |
| DaveGPT inquiry resolution rate at launch | upwards of 89%, serving 9.9 million members[6] | Jan 16, 2024 |
| Q2 2026 revenue / originations | $170.8 million (+30% YoY); ExtraCash originations $2.3 billion (+27%)[2] | Jun 30, 2026 |
| Monthly transacting members | 3.08 million (+17% YoY); 951,000 new members at a $19 acquisition cost[2] | Jun 30, 2026 |
| 28-day past-due rate | 2.12%, improved 14 basis points year over year[2] | Jun 30, 2026 |
| FY2025 revenue and net income | $554.2 million (+60%); net income $195.9 million[4] | Dec 31, 2025 |
| Full-time employees | approximately 280[1] | Dec 31, 2025 |
| ExtraCash fee structure | 5% of the advance, $5 minimum, $15 cap; no instant-transfer fee[9] | Feb 20, 2025 |
“CashAI is a powerful differentiator for Dave, and this latest model underscores our leadership in AI for financial services.”[5]
Jason Wilk · Founder and CEO · Sep 10, 2025
“AI is foundational to how we build, decide and operate across our functions and products.”[11]
Gopi Kuchimanchi · Chief Technology Officer · Jul 7, 2026
“DaveGPT, powered by Aisera, fundamentally impacts how we scale by automating simple interactions and generating value through efficiency and supporting our members.”[6]
Jason Wilk · Founder and CEO · Jan 16, 2024
“On the DOJ matter, we have no updates and continue to vigorously defend our position.”[3]
Jason Wilk · Founder and CEO · Aug 12, 2026
Who runs AI at Dave?
Which regulators govern Dave's AI?
| Authority | Why it matters here | Documents |
|---|---|---|
| Federal Trade Commission (with the US Department of Justice) | The FTC sued Dave on November 5, 2024 under the FTC Act and ROSCA over ExtraCash advertising, undisclosed fees and tips; the DOJ's amended complaint of December 30, 2024 names Dave and CEO Jason Wilk and seeks civil penalties. The case was still pending in August 2026. | |
| CFPB | Dave's 10-K says its activities, directly or through its bank partnership, are subject to Dodd-Frank Title X and CFPB rules; CashAI's automated credit decisions on ExtraCash and the DaveGPT chatbot fall squarely within the CFPB's circulars on algorithmic adverse action and chatbots in consumer finance. | CFPB Circular 2022-03 CFPB Chatbots in Consumer Finance (issue spotlight, 2023) |
| FDIC | Member deposits sit at Evolve Bank & Trust and Coastal Community Bank with FDIC pass-through insurance, and ExtraCash is a bank-issued discretionary overdraft underwritten by Dave's model; the partner banks carry the supervisory obligations for the fintech programme and the model Dave runs for them. | |
| SEC | As a NASDAQ-listed company whose 10-K names CashAI and DaveGPT among its material technologies and AI among its risk factors, Dave's AI disclosures are within the scope of the SEC's investor-advisory recommendations on AI disclosure and its examination focus on AI claims. | Investor Advisory Committee AI disclosure recommendation Division of Examinations FY2026 Priorities |
Linked authorities have a page in the AI Regulation Tracker; the others are named for completeness and not yet tracked.
What does the public record suggest about Dave's AI strategy?
Analysis by BankingNewsAI from the sources cited on this page. Observations, not advice.
01
The AI claim is a credit-model claim, and it is measured in loss rates
Unlike neobanks that lead with a chatbot, Dave's disclosed metrics for CashAI are approval amounts, conversion and the 28-day past-due rate (2.12% in Q2 2026). Each model version is justified by credit performance, which makes the AI story auditable quarter by quarter.
02
v6 is explicitly tuned for profit, not minimum losses
Management's own framing is that CashAI v6 'is designed to expand gross profit dollars within our controlled range of loss rates, not necessarily to drive the lowest possible loss rates'. The model's objective function is commercial, which is relevant to how regulators read automated credit decisions.
03
The enforcement case is about disclosure, not the model
The FTC and DOJ complaints concern advertised amounts, fees and tips; CashAI's underwriting is not alleged to be unfair. But the same complaint says few users received the advertised $500, which is a direct consequence of model-set limits, so the model's outputs are part of the marketing dispute.
04
A bank-partner model means the AI is run for someone else's balance sheet
ExtraCash is a discretionary overdraft issued by Evolve and now funded through Coastal; the partner banks, not Dave, hold the charter and the supervisory obligations for a model they did not build. The 2030-term Coastal agreement makes that dependency long-dated.
05
The generative layer is bought, the underwriting layer is built
DaveGPT is an Aisera product customised for Dave; CashAI is proprietary and trained on Dave's own 180 million originations. The 10-K treats the vendor relationship as a risk factor and the proprietary dataset as the moat.
06
Headcount is small for the volumes handled
About 280 employees supported $2.3 billion of quarterly originations and 3.08 million monthly transacting members in mid-2026, which is only possible because underwriting, fraud and much of support are automated.
How does Dave use AI to decide ExtraCash advances?
Through CashAI, its proprietary underwriting engine. It analyses cash-flow data from a member's primary bank account in real time, hundreds of data points on income, spending and transaction history, and sets the approval amount (up to $500) with no credit check and no FICO score. Dave says CashAI has learned from more than 180 million ExtraCash originations and that the product's roughly 11-day term gives it fast feedback loops. v5.5 went live in September 2025 and v6, with more than 700 features, began rolling out in 2026.
What is DaveGPT and who built it?
DaveGPT is Dave's generative AI customer-service assistant, launched in January 2024 and built on Aisera's platform rather than in-house. It answers member inquiries, sets up direct deposits and handles account management through natural-language chat; Aisera said it resolved upwards of 89% of inquiries for Dave's then 9.9 million members. Dave's 10-K lists it among its AI systems and names the vendor dependency as a risk factor.
Is Dave a bank?
No. Dave is a NASDAQ-listed fintech. Dave Checking accounts, debit cards and the ExtraCash overdraft are issued by partner banks, Evolve Bank & Trust and Coastal Community Bank, which hold member deposits with FDIC pass-through insurance. Since June 2026 ExtraCash receivables are funded through Coastal under a program agreement that runs to 2030.
Why did the FTC and the Justice Department sue Dave?
The FTC filed suit on November 5, 2024 alleging Dave advertised cash advances of up to $500 that few users received, did not disclose up front an instant-transfer fee of up to $25 and a $1 monthly fee, and collected hard-to-avoid tips. The DOJ's amended complaint of December 30, 2024 added CEO Jason Wilk as a defendant and seeks civil penalties. Dave disputes the claims, replaced tips and express fees with a flat 5% fee by February 2025, and said in August 2026 there were no updates on the case.
Who regulates Dave?
Dave is not chartered, so its partner banks are supervised by their banking regulators and member deposits carry FDIC pass-through insurance. Dave itself is subject to the FTC Act and ROSCA (the basis of the pending DOJ/FTC case), to the CFPB under Dodd-Frank Title X, and to SEC disclosure rules as a listed company. CashAI's automated credit decisions sit within CFPB guidance on algorithmic adverse action.
How big is Dave in 2026?
In Q2 2026 Dave reported revenue of $170.8 million (up 30%), ExtraCash originations of $2.3 billion (up 27%), 3.08 million monthly transacting members and a 28-day past-due rate of 2.12%. Full-year 2025 revenue was $554.2 million, up 60%, with net income of $195.9 million. The company had about 280 full-time employees at the end of 2025.
Who leads AI at Dave?
Founder and CEO Jason Wilk fronts the CashAI story on earnings calls and in releases. Gopi Kuchimanchi, appointed Chief Technology Officer in July 2026 after joining in 2021 and serving as VP of Technology from 2023, led the development of CashAI and said AI is foundational to how Dave builds, decides and operates. CFO Kyle Beilman reports the model's credit outcomes.
- Dave Inc. Annual Report on Form 10-K for the year ended December 31, 2025
- Dave Reports Second Quarter 2026 Financial Results
- Dave (DAVE) Q2 2026 Earnings Call Transcript
- Dave Reports Fourth Quarter & Full Year 2025 Financial Results
- Dave Introduces CashAI v5.5
- Aisera & Dave Launch DaveGPT, a Generative AI Customer Service Assistant to Enable Personalized On-Demand Support
- FTC sues fintech app Dave over misleading $500 cash advance ads
- US files complaint against fintech app Dave and its CEO
- Dave Completes Transition to Simplified Fee Structure
- Dave Begins Funding ExtraCash Originations Through Coastal Community Bank
- Dave Appoints Gopi Kuchimanchi as Chief Technology Officer
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