Payday advance app Earnin, which has been downloaded more than 11 million times according to Aptopia data, is on track to become a personal finance platform. It’s building out its feature set through in-app bill management features that let users know when bills are due, negotiating with bill payees and offering cash back rewards.

On Wednesday, the company released a new feature called HealthAid, through which it negotiates with providers to lower customers’ healthcare bills. It also rolled out a cash back rewards program in partnership with 9,200 retailers as part of the announcement.

The feature releases help position Earnin as a holistic platform to manage users’ personal finance needs. They are being released as the app reportedly is being investigated by the New York Department of Financial Services, examining whether the voluntary tips that finance the payday advance payments amount to APRs that exceed allowable limits.

To Earnin, however, the features are part of a broader effort to help users take more control over their financial lives. “Conceptually, our services are so basic, like having access to pay or even affordable healthcare,” said Ram Palaniappan, in an interview with Bank Innovation. “These are really essential services and you don’t want to hold that back.”

Earnin users connect to their bank accounts via APIs. To get set up, they provide Earnin with a pay statement and employer information, and users can get up to $100 per day in advance of payday. Earnin then carries out a direct debit from the individual’s bank account that’s synchronized with their pay schedule.

Unlike payday loans or other payday advance apps that charge monthly fees or interest rates, Earnin generates most of its revenues from voluntary tips users pay, an amount that’s typically between less than a dollar and $14 (those who don’t leave a tip can still use the payday advance service). While Earnin promotes itself at workplaces, unlike services such as Even or Flexwage, it doesn’t integrate directly with employers’ HR and pay systems.

Another unique feature it uses for non-remote employees is GPS verification to track whether employees are going to work. Remote workers don’t need to enter GPS information, and some remote platforms like Uber have built-in integrations with Earnin, Palaniappan noted.

To industry watchers, Earnin represents a challenge and an opportunity. Leslie Parrish, senior analyst at Aite Group, said Earnin’s model has the capacity to reach a wide group of users, but there are questions around user safeguards when the employer isn’t involved in offering payday advances and it doesn’t prevent customers from falling into financial difficulties.

“The opportunity is the ability to reach a lot more consumers [than payday advance apps that connect directly with employers] and they can continue to use Earnin if they change jobs, but the challenge is [the lack of] employer-based protections,” Parrish said. Other risks are instances where employees are double dipping into additional payday advance services and potentially falling into deeper debt traps.

Others argue Earnin resembles a payday loan without regulatory oversight. Scott Astrada, director of federal advocacy at the Center for Responsible Lending, said apps like Earnin don’t verify individuals’ ability to pay and they risk compromising users’ financial health if they are taking out other loans concurrently or have other debts to pay.

“Our main concern is whether this is truly a wage advance product or is it a loan with different logistics or processes, especially if it’s through an ACH from the consumer’s bank account,” Astrada said. “It has all the makings of a payday loan that compromises the financial stability of the borrower, and it’s a slippery slope where loan regulations for small-dollar lending don’t apply.”

Earnin, however, considers its tip-based “paying it forward” approach a new model that’s different from a loan. “It’s a non-recourse liquidity product,” Palaniappan said. “Essentially we’re giving people money without the requirement for a fee and without the right to collect on it.”