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What Is Cash Advance APR? The Math Behind 391%

By Greg HalloranWhat it costs

What Is Cash Advance APR? The Math Behind 391%

Cash advance APR is a flat fee restated as a yearly rate. Take the fee, divide by the amount borrowed, multiply by 365, divide by the number of days you have the money. A $15 fee on $100 for 14 days works out to 391% APR. Stretch that same $15 over 30 days and the APR drops to 183%. The fee didn't change. The calendar did.

That's the whole idea in one paragraph. The rest of this guide shows where the formula comes from, why 391% appears in nearly every government example, and what happens when you run the same arithmetic on a credit card advance, a paycheck app, and the fee caps in Florida, California, Washington, and Texas.

The four-line calculation you can do on your phone

Regulation Z, the rule that implements the Truth in Lending Act, defines the annual percentage rate as "a measure of the cost of credit, expressed as a yearly rate, that relates the amount and timing of value received by the consumer to the amount and timing of payments made" (12 CFR 1026.22). The official method lives in Appendix J of the regulation, and for a loan with several payments it takes a spreadsheet. For a loan you repay in one lump sum, it collapses to four lines.

Here is the St. Louis Fed's version, using $300 borrowed with a $45 fee for 14 days:

  1. Fee divided by amount: $45 / $300 = 0.15
  2. Times 365: 0.15 x 365 = 54.75
  3. Divided by days: 54.75 / 14 = 3.91
  4. Times 100 to make it a percentage: 391%

Line one is the cost per dollar for the period. Lines two and three scale that period up to a year. That's it. Nobody charges you 391% of anything; you pay $45. The APR just tells you what $45 for two weeks would look like if you kept paying it at the same pace for twelve months.

I round to the nearest whole percent throughout. Lenders disclose to two decimals (391.07% here), and Regulation Z gives them a tolerance of one eighth of a percentage point, so a disclosure that reads 391.07% and my 391% are the same number.

Why 391% shows up in every regulator's example

Three federal sources use the same inputs. The FTC says $15 per $100 on a two-week loan "translates to an annual percentage rate (APR) of 391%." The CFPB runs the identical example and rounds it to "almost 400 percent." The St. Louis Fed's Page One Economics lesson walks through the $45-on-$300 arithmetic above. Same fee, same term, same answer.

The $15 figure isn't arbitrary. Pew's 2016 fact sheet put payday loans in 36 states at "annual percentage rates averaging 391 percent," a figure built from what state law permitted on a two-week loan at the time. Most lenders charge the state maximum, and a lot of state maximums landed near $15 per $100. So the number in the textbook and the number on the storefront disclosure converged.

Averages hide the spread, though. The St. Louis Fed's 2019 sample ran from 175% in New Mexico (since capped at 36%) to 661% in Texas, and the Center for Responsible Lending's 2023 map spans 140% to 662% across the 28 states that still permit the product. Texas's own regulator, the Office of Consumer Credit Commissioner, put payday APRs at 365% to 496% in its December 2025 loan comparison.

One formula, every product

The table below runs the four-line calculation on payday fees at state caps, a credit card advance, and paycheck-app fees. Every input comes from a statute, a regulator report, or a CFPB example, and every APR is my own arithmetic from those inputs. The fee column is the finance charge; the total is what you hand back.

Single-payment APR = fee / amount x 365 / days, rounded to the nearest whole percent. Credit card rows are illustrations of all-in cost, not the APR an issuer discloses.
Product and source of inputsAmountTermFeeTotal repaidAPR
FTC and CFPB example, $15 per $100$10014 days$15.00$115.00391%
Low end of the CFPB's $10 to $30 range$10014 days$10.00$110.00261%
High end of that range$10014 days$30.00$130.00782%
Same $15 fee, 30-day term$10030 days$15.00$115.00183%
Florida cap: 10% plus $5 verification (Fla. Stat. 560.404, 560.309)$50014 days$55.00$555.00287%
Florida cap at the 31-day maximum term$50031 days$55.00$555.00130%
California cap: 15% of a $300 check, $255 in hand (Cal. Fin. Code 23036)$25514 days$45.00$300.00460%
Washington cap: 15% on the first $500 (RCW 31.45.073)$50014 days$75.00$575.00391%
Washington 2024 actual averages (DFI report)$471.2941.5 days$59.37$530.66111%
Credit card: 5% fee plus 30% rate, repaid in 30 days (CFPB norms)$50030 days$25.00 fee + $12.33 interest$537.3391% all-in
Credit card, same terms, repaid in 90 days$50090 days$25.00 fee + $36.99 interest$561.9950% all-in
Paycheck app, CFPB average transaction$10610 days$3.18$109.18110%
Paycheck app, small and fast (CFPB example)$504 days$3.18$53.18580%
Direct-to-consumer app (CFPB example)$1447 days$8.00$152.00290%

A few rows deserve their arithmetic in full.

Florida: 10% of $500 is $50, plus the $5 verification fee the statute allows, so $55. $55 / $500 = 0.11. 0.11 x 365 = 40.15. 40.15 / 14 = 2.87, or 287%. Hold the same $55 for the 31-day maximum term and the last line becomes 40.15 / 31 = 1.30, or 130%.

California: the statute caps the check at $300 and the fee at 15% of the check's face, which is $45. You walk out with $255 and hand back $300. $45 / $255 = 0.1765. 0.1765 x 365 = 64.41. 64.41 / 14 = 4.60, or 460%. The APR is higher than Washington's on the same 15% because the fee is measured against $300 but you only received $255.

Washington's real numbers: the state Department of Financial Institutions reported an average 2024 loan of $471.29, an average fee of $59.37, and an average term of 41.5 days. $59.37 / $471.29 = 0.1260. 0.1260 x 365 = 45.98. 45.98 / 41.5 = 1.11, or 111%. Same 15% cap as the 391% row above, less than a third of the APR, because borrowers took six weeks instead of two.

The CFPB's average app transaction: $3.18 / $106 = 0.03. 0.03 x 365 = 10.95. 10.95 / 10 = 1.095, which the CFPB reports as 109.5%. For the $50 advance repaid in four days: $3.18 / $50 = 0.0636. 0.0636 x 365 = 23.21. 23.21 / 4 = 5.80, or 580%.

Why the same fee can be 130% or 782%

Two inputs move the number: the fee per $100 and the number of days. Look back at the table. A $15 fee is 391% at 14 days and 183% at 30 days. A 14-day term is 261% at $10 per $100 and 782% at $30 per $100. Florida's fee never changes between its two rows, and the APR still drops from 287% to 130% when the borrower takes the full 31 days.

This is why "what is the cash advance APR" has no single answer. The APR is a rate of spending, not a price. When you compare offers, compare the dollar fee for the days you'll actually use, then check the APR to see whether the price per day is out of line.

Credit card cash advance APR is a different animal

The "cash advance APR" printed on a credit card agreement is a real interest rate, not a converted fee. The CFPB's December 2024 spotlight says the most common cash advance fee is the greater of $10 or 5%, that 30% is "the norm for cash advance rates," and that interest runs "from the date of the transaction." No grace period. Cardholders paid $717 million in cash advance fees on $3.6 billion of advances in 2022.

What the disclosed rate leaves out is the transaction fee. Open-end credit follows 12 CFR 1026.14, which sets the APR as the periodic rate times the periods in a year; the up-front fee is a finance charge but isn't folded into that number the way Appendix J folds a payday fee in. So to compare a card advance to a payday advance you have to add the fee back yourself.

Take $500 at a 5% fee ($25) and a 30% rate, repaid after 30 days. Interest is $500 x 0.30 x 30 / 365 = $12.33. Total cost $37.33. Convert: $37.33 / $500 = 0.0747. 0.0747 x 365 = 27.25. 27.25 / 30 = 0.91, or about 91% all-in. Carry it 90 days instead: interest is $500 x 0.30 x 90 / 365 = $36.99, total cost $61.99, and $61.99 / $500 x 365 / 90 = 0.50, about 50%. The card gets relatively cheaper the longer you carry it, because the fixed $25 gets spread thinner, which is the opposite of what your statement balance will feel like.

For scale, the Federal Reserve's G.19 release for the second quarter of 2026 shows credit card accounts assessed interest averaging 22.83%, and a 24-month personal loan averaging 11.14%. A 30% cash advance rate sits well above both before the fee is counted.

App advances show no APR, so here is the CFPB's

Since December 23, 2025, the CFPB's advisory opinion in the Federal Register says expedite fees and tips on covered earned wage access products "are not, in the normal course, finance charges." No finance charge means no Truth in Lending APR on the screen. The opinion covers employer-based programs and doesn't address direct-to-consumer apps, but in practice you'll rarely see a percentage on either.

The CFPB did the arithmetic anyway in its July 2024 market spotlight: 109.5% on the average transaction and 580.4% on a $50 advance repaid in four days. The Center for Responsible Lending's 2024 transaction study found an average of 367% for advances repaid in 7 to 14 days; that's an advocacy group's calculation, so I'd pair it with the CFPB's figures rather than lean on it alone. The range is wide because the fee is flat and the amounts are small. A borrower in one CRL diary put it plainly: "each month I probably spend close to $40 just on fees." That's payday-fee money; the app just never printed the rate.

What the APR leaves out

APR prices one loan for one term. It says nothing about the second loan. The CFPB's rollover example takes a $300 loan with a $45 fee, rolls it once, and the cost doubles to $90 while the APR on each individual loan stays exactly where it was. Pew found the typical borrower paying $520 in fees to repeatedly borrow $375, which is more than the principal, and no single-loan APR can show that. The blind spot runs the other way too: Washington's 41.5-day average turns a 391% cap into 111%, and the borrower still paid $59.37.

State caps that change the answer

Your state sets the fee, so your state sets the APR. The site's state pages carry the exact rule and statute for every state; here are the ones behind the table above, plus the caps that reset the whole calculation.

State rules behind the APRs in this guide. Sources: state statutes and regulator reports as named; the 36% state count is CRL's, January 2025.
State or groupRuleWhat it means on $100 for 14 days
20 states plus DC36% all-in cap, or no single-payment product36%, which is $1.38
Minnesota36% cap effective January 2024 (Minn. Stat. 47.60)36% at the base tier
Rhode Island36% cap effective January 1, 202736% from 2027
Florida10% plus $5 verification (560.404, 560.309)287%, which is $11.00 on $100
California15% of a $300 check (Fin. Code 23036)460% on the $255 in hand
Washington15% on the first $500, 10% above (RCW 31.45.073)391%, which is $15.00
TexasCredit access business fees uncapped; lender interest 10% (OCCC)365% to 496% in OCCC's examples

The 36% figure at 14 days: $100 x 0.36 x 14 / 365 = $1.38. That's the all-in price under the Military Lending Act for active-duty borrowers and their dependents, and under Illinois's Predatory Loan Prevention Act, which borrowed the MLA's method. Some reform states (Colorado, Hawaii, Ohio, Virginia) replaced the two-week loan with longer installment loans instead; Pew's 2022 brief reports those cost about four times less than single-payment loans in states with few protections. Installment caps vary too: NCLC's December 2025 survey puts the median state cap for a $500 six-month loan at 39.5%.

Put your own numbers in

The cash advance calculator on this site runs the four lines for any fee, amount, and term. This site is a loan-request service, not a lender; the APR that counts is the one on the disclosure your lender hands you before you sign, and Regulation Z requires that disclosure for every closed-end cash advance. Use the calculator to check it. If the fee is $15 per $100 and you'll have the money 14 days, expect to see 391%. If the fee is the same and your next paycheck is 25 days out, expect $15 / $100 x 365 / 25 = 219%. Either way you pay $15, and either way that $15 comes out of the next check.

Sources

State caps, maximum terms and the regulator for your state are cited on the state pages.

Frequently Asked Questions

Is 391% APR real?

Yes, as a rate. It's the Truth in Lending conversion of a $15 fee per $100 over 14 days: 0.15 x 365 / 14 = 3.91. The FTC, the CFPB, and the St. Louis Fed all publish this example. What's not real is the idea that you pay 391% of anything; on $100 for two weeks you pay $15.

Do I pay 391% of the loan?

No. You pay the fee for the days you borrow. 391% is what that fee would add up to if you paid it every two weeks for a year: 365 / 14 is about 26 periods, and 26 x $15 is roughly $391 on $100. It only becomes your real cost if you keep rolling the loan over.

Why is my credit card's cash advance APR higher than my purchase APR?

Issuers price cash advances as a separate, riskier product: the CFPB reports 30% as the norm against a 22.83% average on all interest-bearing accounts in the Fed's second-quarter 2026 data. The advance also carries a fee (typically the greater of $10 or 5%) and accrues interest from day one with no grace period. The disclosed APR under 12 CFR 1026.14 excludes that fee, so the all-in cost for a short hold is higher still.

Is a 36% cap the same as a 36% loan?

No. A cap is a ceiling. Under a 36% cap, $100 for 14 days costs at most $100 x 0.36 x 14 / 365 = $1.38, and a lender can charge less. Some caps, like the Military Lending Act's, are all-in and count most fees; others count interest only, which is why NCLC and CRL track what each state's cap includes.

Do cash advance apps have an APR?

Usually not on the screen. The CFPB's December 2025 advisory opinion says tips and expedite fees on covered earned wage access products aren't finance charges, so no Truth in Lending APR is required. You can compute one yourself with the same formula: the CFPB's own examples come to 109.5% on an average $106 advance for 10 days and 580.4% on $50 for four days.

Not a lender. Cost figures use the federal APR formula and the state rule named next to them; the state pages cite each statute. Full disclosures.

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