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Wages Loans Payday Loans

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

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

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

DailyPay, Inc.

Earned Wage Access: The Anti-Loan

DailyPay, Inc. on

Currently, more than 60% of Americans are living paycheck-to-paycheck. And for the average American household, emergency expenses don’t always align perfectly with the typical biweekly payday. This financial strain leads...more

Ballard Spahr LLP

Earned Wage Access Products Are Not Loans, According to the AG of Montana

Ballard Spahr LLP on

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

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

DailyPay, Inc.

Earned Wage Access & the Fintech Fight for Financial Equity

DailyPay, Inc. on

As Black History Month comes to a close, the relationships between the history of race, poverty, affordable financial services, and modern American life are hard to ignore. Over the past two years, surviving a pandemic has...more

Allen Matkins

But Is It A Loan?

Allen Matkins on

Earlier this week, California' Department of Financial Protection & Innovation announced that it had entered into memorandums [sic] of understanding with five earned wage access companies.  If you haven't heard of a "earned...more

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