News & Analysis as of

Credit Regulation Z Debt

McGlinchey Stafford

Credit, Tips, Obligation to Pay: CFPB Proposed Interpretive Rule Seeks to Clarify Earned Wage Access and Regulation Z

McGlinchey Stafford on

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....more

Hudson Cook, LLP

Income Share Agreements - Operating Under Current Regulations and Preparing for the Future

Hudson Cook, LLP on

The Income Share Agreement ("ISA") market is rapidly developing with more providers offering ISA programs to students and outside money moving into the space. However, the legal environment remains uncertain, and providers...more

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