News & Analysis as of

Wage and Hour › Truth in Lending Act (TILA) › Payday Loans

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

Troutman Pepper

California DFPI’s Proposed EWA Legislation Rejected by Office of Administrative Law

Troutman Pepper on

As discussed here, in March 2023, the California Department of Financial Protection and Innovation (DFPI) proposed new regulations under the California Financing Law that would interpret the definition of “loan” to include...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

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

New Jersey Bill Would Prohibit Certain Wages-on-Demand Services and Regulate Others

Womble Bond Dickinson on

In 2019, California was the first state to take a swing at explicitly regulating wages-on-demand services. The state senate considered a bill that would provide exemptions to payday lending, money transmission, and financing...more

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