On October 11, California’s Office of Administrative Law (“OAL”) approved the Department of Financial Protection and Innovation’s (“DFPI’s”) registration rulemaking for providers of the following products...more
11/1/2024
/ California Consumer Financial Protection Law (CCFPL) ,
Comment Period ,
Consumer Financial Products ,
Debt Settlement Services ,
Debt-Relief Industry ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Services Industry ,
Income Share Agreements ,
Office of Administrative Law Judges (OALJ) ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process
Today’s podcast, which repurposes a recent webinar, is the conclusion of a two-part examination of the CFPB’s use of a proposed interpretive rule, rather than a legislative rule, to expand regulatory requirements for earned...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
5/31/2024
/ Consumer Financial Products ,
Earned Wage Access ,
EFTA ,
Electronic Fund Transfer Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
New Regulations ,
Payday Loans ,
Wage and Hour ,
Wages
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
1/8/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Earned Wage Access ,
Financial Services Industry ,
Loans ,
Montana ,
Payday Lending Rule ,
Payday Loans ,
State Attorneys General ,
Statutory Interpretation ,
Wage and Hour ,
Wages