News & Analysis as of

Wage and Hour › Consumer Financial Protection Bureau (CFPB) › Consumer Financial Products

Manatt, Phelps & Phillips, LLP

Why The CFPB’s Earned Wage Access Rule Is Subject To Challenge

Manatt, Phelps & Phillips, LLP on

Earned wage access (“EWA”) programs are financial products that allow workers to receive payment for wages they have already earned before their next scheduled payday. Many of these programs are integrated into their...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Troutman Pepper

CFPB Says Earned Wage Access Products are Subject to the Truth in Lending Act

Troutman Pepper on

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more

Akerman LLP

Explainer Things: Season 2 Episode 3

Akerman LLP on

It has been a busy time for us at Explainer Things. Awards season is over, but the fintech regulatory drama is in midseason form. The star of this episode is of course the Supreme Court’s decision on the future of the CFPB....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

Troutman Pepper

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

Troutman Pepper on

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

Ballard Spahr LLP on

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

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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

Hudson Cook, LLP

Earned Wage Access - Now with Fees: A Low-Cost Credit Alternative or State Regulatory Minefield?

Hudson Cook, LLP on

We recently wrote about the Consumer Financial Protection Bureau's November 2020 advisory opinion regarding earned wage access (EWA) programs. In that opinion, the CFPB determined that earned wage access programs — when...more

Womble Bond Dickinson

What Employers Need to Know About Advance Wage Payment Products

Womble Bond Dickinson on

A hot topic of discussion in payroll offices around the country is the prospect of new services that provide workers with immediate access to their wages for hours they have worked but which aren’t due to be paid until after...more

Carlton Fields

CFPB Proposes Banning Use of Pre-Dispute Arbitration Agreements in Consumer Class Actions

Carlton Fields on

The Consumer Financial Protection Bureau (CFPB or Bureau) announced today that it is considering rules prohibiting application of pre-dispute arbitration agreements to class litigation involving certain consumer financial...more

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