News & Analysis as of

Wage and Hour Truth in Lending Act (TILA) Earned Wage Access

Morgan Lewis

Earned Wage Access: New California Regulations Underline Patchwork Approach to Industry

Morgan Lewis on

By approving a framework regulating earned wage access (EWA), California contributes to a state-by-state patchwork of EWA regulation. With the future of federal action uncertain, EWA providers will have to navigate this...more

Manatt, Phelps & Phillips, LLP

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

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

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

Troutman Pepper

Arizona, Kentucky, and Hawaii Become Latest States to Introduce Legislation to Regulate Earned Wage Access Products

Troutman Pepper on

Recently, Arizona, Kentucky, and Hawaii have jumped on the bandwagon to regulate earned wage access (EWA) products and services. Arizona’s proposed bill makes clear that EWA services are not considered to be loans or money...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

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