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Wages › Rulemaking Process › Truth in Lending Act (TILA)

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

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Interpretive Rule Characterizing Earned Wage Access Products as Loans

Sheppard Mullin Richter & Hampton LLP on

On July 18, the CFPB proposed a new interpretive rule that would characterize earned wage access (“EWA”) products as extensions of credit and subject to the Truth in Lending Act and Regulation Z. Under the interpretive...more

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