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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
Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...more
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
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
On May 21, 2024, South Carolina Governor Henry McMaster signed into law the Earned Wage Access Services Act (the “Act”), which will require earned wage access (“EWA”) providers to register annually with the state’s Department...more
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
The American Fintech Council (AFC), a trade group whose members include providers of earned wage access (EWA) products, has sent a letter to Director Chopra urging the CFPB to take steps towards development of a “pragmatic...more
On August 28, 2023 (the “Effective Date”), SB 103, signed into law by Missouri’s governor, will become the nation’s second statutory framework for earned wage access (EWA) providers. The Missouri law closely resembles...more
In June, the Nevada governor signed SB 290 into law, making Nevada the first state to enact legislation creating a comprehensive statutory framework that specifically defines and regulates the provision of earned wage access...more
On June 13, Nevada’s governor signed into law Senate Bill 290 creating the nation’s first statutory framework for earned wage access (EWA) providers operating in the state. The law appoints the state’s Commissioner of...more