The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA)...more
3/17/2025
/ Consumer Financial Products ,
Data Privacy ,
Debt Collection ,
Earned Wage Access ,
Employees ,
Enforcement Actions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Independent Contractors ,
Pending Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Wage and Hour ,
Wages
Last month, we discussed the California Department of Financial Protection and Innovation’s (DFPI) newly approved regulations for direct-to-consumer earned wage access (EWA) products. These regulations, approved by the Office...more
11/26/2024
/ California Consumer Financial Protection Law (CCFPL) ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Regulatory Requirements ,
Wage and Hour
On October 11, the Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on direct-to-consumer (i.e., non-employer offered) earned wage...more
10/24/2024
/ Banks ,
California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Office of Administrative Law Judges (OALJ) ,
Wage and Hour
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
7/22/2024
/ Borrowers ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payday Loans ,
Proposed Rules ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
The California Department of Financial Protection and Innovation (DFPI) has once again modified its proposed rulemaking on earned wage access (EWA) products. As discussed here, this spring the Office of Administrative Law...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
5/7/2024
/ California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Office of Administrative Law ,
Office of Administrative Law Judges (OALJ) ,
Payday Loans ,
Proposed Regulation ,
Regulatory Agenda ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
On April 19, Kansas Governor Laura Kelly signed House Bill (HB) 2560 to regulate earned wage access (EWA) products and services. HB 2560 enacts the Earned Wage Access Services Act that requires EWA providers to be licensed by...more
4/26/2024
/ Banks ,
Consumer Financial Products ,
Disclosure Requirements ,
Earned Wage Access ,
Electronic Fund Transfer Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
New Legislation ,
Payday Loans ,
Popular ,
Wage and Hour
On February 20, the Wisconsin Senate passed House Bill (HB) 574 to regulate earned wage access (EWA) products and services. HB 574 creates a new chapter to the Wisconsin Statutes that requires EWA providers to be licensed by...more
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
2/2/2024
/ Arizona ,
Consumer Financial Products ,
Debt ,
Debt Collectors ,
Earned Wage Access ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Payday Loans ,
State and Local Government ,
Truth in Lending Act (TILA) ,
Unpaid Wages ,
Wage and Hour ,
Wages
On December 22, Montana Attorney General Austin Knudsen issued an opinion on whether Earned Wage Access (EWA) products constitute either “consumer loans” under Montana Code § 32-5-102(2)(a) or “deferred deposit loans” under §...more
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
12/7/2023
/ California ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Financial Protection and Innovation (DFPI) ,
Employees ,
Financial Services Industry ,
Loans ,
New Regulations ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
On August 1, Maryland’s Office of Financial Regulation (OFR) issued guidance to “provide clarity on how [the OFR] views Earned Wage Access [EWA] products and to describe the requirements entities offering these products must...more
8/21/2023
/ Consumer Financial Products ,
Earned Wage Access ,
Fees ,
Financial Services Industry ,
Maryland ,
OFR ,
Payday Lending Rule ,
Payday Loans ,
Third-Party ,
Tips ,
Wage and Hour
On July 7, Missouri Governor Mike Parson signed SB 103 into law, which prohibits any person from offering earned wage access (EWA) services without registering with the Division of Finance and paying an annual $1,000 fee. The...more
7/13/2023
/ Consumer Financial Products ,
Credit Reports ,
Credit Scores ,
Earned Wage Access ,
Electronic Fund Transfer Act ,
Financial Services Industry ,
New Legislation ,
Payday Lending Rule ,
Popular ,
Regulatory Requirements ,
Wage and Hour ,
Wages