On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more
7/25/2024
/ Buy Now Pay Later (BNPL) ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interpretive Rule ,
Loans ,
Payday Loans ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
On May 21, 2024, South Carolina Governor Henry McMaster signed into law the Earned Wage Access Services Act (the “Act”), which will require earned wage access (“EWA”) providers to register annually with the state’s Department...more
5/31/2024
/ Consumer Financial Products ,
Earned Wage Access ,
EFTA ,
Electronic Fund Transfer Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
New Regulations ,
Payday Loans ,
Wage and Hour ,
Wages
On December 22, 2023, the Attorney General of Montana released an opinion (the “Opinion”) concluding that certain earned wage access (EWA) products are not “consumer loans” or “deferred deposit loans” under Montana law and do...more
1/8/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Earned Wage Access ,
Financial Services Industry ,
Loans ,
Montana ,
Payday Lending Rule ,
Payday Loans ,
State Attorneys General ,
Statutory Interpretation ,
Wage and Hour ,
Wages