CRL highlights the harms consumers face in the District of Columbia, which are similar to those associated with storefront payday loans. CRL offers its recommendations to the District of Columbia to consider as it moves forward with investigating and addressing payday loan apps. We recommend developing guidance to affirm the status of payday loan apps as credit under existing law, applying DC’s 24% rate cap to payday loan apps without exemption or exception, and looking to the experience of other states to clamp down on exploitative, predatory lending.