In a testimony to the US Senate Committee on Banking, Housing and Urban Affairs on New Consumer Financial Products and The Impact to Workers, Rachel Gittleman, Consumer Federation of America’s Financial Services Outreach Manager, urged the Committee to meaningfully address the potential risks that emerging fintech products pose for consumers. There has been an explosion of these new credit products (ex. buy now, pay later, training repayment agreements, earned wage access, and products that use a “tips” model) across the marketplace, and although each is unique, they share one thing in common: they disguise credit and the true cost to consumers and regulators. While these consumer credit products and fee models are each unique, they share similarities in how they operate and how they use “innovation,” to claim that they do not fit within the existing regulatory framework. Regardless of their structure, each of these products are credit – they provide funding today and are repaid at a later date. Given that, these products should be subject to the host of state and federal consumer protection laws that regulate credit products