News & Analysis as of

Loans Wage and Hour

Ballard Spahr LLP

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

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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

Mayer Brown

The State of Play on EWA

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Like a snowball rolling down a hill, the push to pass legislation to regulate earned wage access (EWA) providers is growing. In June 2023, Nevada became the first state to officially regulate earned wage access providers, and...more

Ballard Spahr LLP

Earned Wage Access Products Are Not Loans, According to the AG of Montana

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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

Orrick, Herrington & Sutcliffe LLP

Montana AG opines that EWA products are not loans

On December 22, the Attorney General from the State of Montana opined that Earned Wage Access (EWA) products are not loans under a certain set of conditions. EWA products provide employees with fast access to cash by...more

Troutman Pepper

Montana AG Opines That Earned Wage Access Products Do Not Constitute Loans

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On December 22, Montana Attorney General Austin Knudsen issued an opinion on whether Earned Wage Access (EWA) products constitute either “consumer loans” under Montana Code § 32-5-102(2)(a) or “deferred deposit loans” under §...more

Ballard Spahr LLP

CFPB comments on California proposal to supervise providers of earned wage access products

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The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances”...more

Troutman Pepper

CFPB Issues Letter Supporting California DFPI’s Proposed Classification of EWAs as Loans and Promises Guidance as to Federal...

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In March 2023, the California Department of Financial Protection and Innovation (DFPI) proposed new regulations under the California Financing Law that would update the definition of loan to include what it dubs as...more

Davis Wright Tremaine LLP

Georgia Becomes Latest to Address Earned Wage Access Providers

On February 26, 2021, Georgia introduced HB 674, which would authorize earned wage access (EWA) providers to operate in the state and avoid loan characterization by meeting certain requirements, including registration....more

Robins Kaplan LLP

Financial Daily Dose 7.15.2020 | Top Story: America’s Biggest Banks Setting Aside Tens of Billions for Anticipated Loan Losses

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The latest quarterly reporting shows that America’s biggest banks—among them, JPMorgan, Citigroup, and Wells Fargo—are taking self-imposed hits now in anticipation of a “wave of loan losses” later. Those three are...more

White & Case LLP

COVID-19 – The Russian government’s measures to support the Russian economy

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Since March 2020, the Russian authorities have taken a number of measures to mitigate the effect of COVID-19 on the Russian economy. The range of measures is very broad. Some measures are directed at wide categories of...more

Goodwin

COVID-19 Briefing – Germany Agrees to Unprecedented Package to Protect Businesses

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On 13 March 2020, the German government agreed on a far-reaching package of measures to protect companies and businesses in the German market. The central message is that the Federal State (Bund) and the provinces...more

McDermott Will & Emery

Changes in Executive Compensation

In a presentation at McDermott’s Employment and Employee Benefits Forum, Andrew Liazos discussed areas of focus for Section 162(m) and third-party loan funding for employee stock purchase plans (ESPPs). He also provided...more

Goodwin

Financial Services Weekly News - November 2016 #4

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Editor's Note - Potential CFPB Reform in the Wake of the Election. The November 16 edition of the Roundup indicated that the Financial CHOICE Act (Act) may be a blueprint for legal changes affecting the financial...more

McDermott Will & Emery

Gesetzentwurf sieht Höchstüberlassungsdauer von 18 Monaten für Leiharbeitnehmer vor

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Der Gesetzesentwurf, der heute der deutschen Presseagentur präsentiert wurde, ist noch nicht veröffentlicht. Nach übereinstimmenden Pressemeldungen sieht der Entwurf von Bundessozialministerin Andrea Nahles vor, dass für...more

Ballard Spahr LLP

Loan Officers Petition D.C. Circuit To Review Decision Regarding Overtime Exemption

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Three loan officers at Quicken Loans Inc. have petitioned the U.S. Court of Appeals for the District of Columbia Circuit for en banc reconsideration of a recent ruling that invalidated U.S. Department of Labor (DOL) guidance...more

Fisher Phillips

Quick Quiz: Recovering Loans Or Advances

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Gloria is a stock clerk for The Warehouse Company. She is paid on an hourly basis at the rate of $8.00 per hour. Gloria experiences a personal financial emergency....more

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