News & Analysis as of

Wage and Hour › Truth in Lending Act (TILA) › Regulation Z

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

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...

Troutman Pepper on

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

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

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