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Earned Wage Access

Orrick, Herrington & Sutcliffe LLP

Maryland enacts new earned wage access law

On May 25, the Maryland General Assembly chaptered HB 1294 and affirmatively subjected earned wage access products to the Maryland consumer credit and licensing provisions. The law requires companies that offer earned wage...more

Orrick, Herrington & Sutcliffe LLP

California DFPI releases annual activity report

On May 29, the DFPI released its 2024 Annual Report of Activity under the California Consumer Financial Protection Law (CCFPL), highlighting regulatory activity, investigations, and public actions taken under the CCFPL....more

Ballard Spahr LLP

Maryland enacts Earned Wage Access legislation

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A new Maryland law deems certain earned wage access (EWA) services to be loans. It then subjects those EWA services to the Maryland Consumer Loan Law and other consumer credit provisions, restricts the acceptance of tips by...more

Sheppard Mullin Richter & Hampton LLP

Maryland Enacts Earned Wage Access Law

On May 28, Maryland Governor Wes Moore signed House Bill 1294 into law, establishing a comprehensive regulatory framework for Earned Wage Access (EWA) providers operating in the state. Effective October 1, the new law...more

McGuireWoods LLP

Indiana, Maryland Become Latest States to Enact Legislation Regulating Earned Wage Access

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Indiana and Maryland join seven other states in enacting laws that specifically regulate earned wage access (EWA) providers. EWA is an on-demand payment product that allows workers to access their wages as they are...more

Goodwin

Maryland Enacts Law Regulating Earned Wage Access Services

Goodwin on

Maryland has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Payactiv

Maryland Enacts Landmark Earned Wage Access Legislation

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On May 27, 2025, Maryland enacted first-of-its-kind earned wage access (EWA) legislation to ensure Maryland workers are able to retain continued access to this valuable employee benefit. This landmark legislation follows...more

Davis Wright Tremaine LLP

Previewing Consumer Financial Enforcement in California During the Second Trump Administration

During the first Trump Administration, in response to federal financial agencies adopting a deregulatory approach, several states became more active in the enforcement of consumer financial statutes and regulations to fill...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Dozens of Guidance Documents as Part of Deregulatory Push

On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more

Sheppard Mullin Richter & Hampton LLP

Indiana Enacts Earned Wage Access Law 

On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage...more

Goodwin

Indiana Enacts Law Regulating Earned Wage Access Services

Goodwin on

Indiana has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Hudson Cook, LLP

State Watch: Consumer Protection Enforcement Update

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While uncertainty continued to loom over the CFPB, the states did not take a spring break. Instead, we saw an eye-popping settlement from NY DFS involving BSA/AML claims. And both republican and democratic AGs continued to...more

Payactiv

Late Fee Crunch: How Earned Wage Access Helps Consumers Avoid Penalties

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$23 billion. That’s how much Americans paid in late fees last year. When a payment is only a few days behind, late fees for credit cards, utilities, student loans, and rent pile up. And they have proliferated over the last...more

Mayer Brown

Arkansas and Utah Enact Laws to Regulate Earned Wage Access Providers

Mayer Brown on

Just days apart, Arkansas and Utah enacted laws to regulate providers of earned wage access (“EWA”) services, joining the handful of states that have enacted legislation to regulate these products since 2022. Arkansas House...more

Orrick, Herrington & Sutcliffe LLP

New York attorney general files two complaints against wage access providers

On April 14, the Attorney General (AG) for the State of New York filed two complaints in the New York State Supreme Court, alleging two earned wage access (EWA) providers violated civil and criminal usury provisions, as well...more

Sheppard Mullin Richter & Hampton LLP

New York AG Sues Earned Wage Access Companies for Allegedly Unlawful Lending Practices

On April 14, New York Attorney General Letitia James announced two separate lawsuits against earned wage access providers—one against a company that issues advances directly to consumers, and another targeting a provider that...more

Troutman Pepper Locke

EWA Provider Sues New York Attorney General Over Threatened Enforcement Action

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On April 7, DailyPay, LLC, an employer-integrated earned wage access (EWA) provider, filed a lawsuit against New York Attorney General Letitia James, seeking declaratory relief to prevent the enforcement of state and federal...more

Orrick, Herrington & Sutcliffe LLP

Complaint challenges New York attorney general’s classification of earned wage access as a loan

On April 7, an earned wage access (EWA) provider filed a complaint seeking declaratory relief against the New York Office of the Attorney General (OAG) in U.S. SDNY. The plaintiff requested relief from the OAG’s enforcement...more

Sheppard Mullin Richter & Hampton LLP

Utah and Arkansas Enact Earned Wage Access Regulations

Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more

Orrick, Herrington & Sutcliffe LLP

Arkansas enshrines earned wage access provisions into law

On March 20, the Governor of Arkansas enacted HB 1517 (the “Act”), which establishes the state’s Earned Wage Access (EWA) Services Act. The legislation regulates the business of providing consumers access to their “earned but...more

Orrick, Herrington & Sutcliffe LLP

Utah enacts its Earned Wage Access Services Act

On March 25, the governor of Utah signed into law HB 279, titled the “Earned Wage Access Services Act,” (the “Act”), which establishes regulations for earned wage access services that involve the payment of funds to consumers...more

Goodwin

Utah Becomes Seventh State to Enact Law Regulating Earned Wage Access Services

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Utah has become the seventh state (and the second in 2025) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – March 2025 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Troutman Pepper Locke

Arkansas Passes Earned Wage Access Services Act

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On March 20, the Arkansas governor signed into law Arkansas Act 347, known as the Earned Wage Access Services Act. Sponsored by Representative David Ray (R) and Senator Ben Gilmore (R), this legislation aims to regulate...more

Goodwin

Arkansas Becomes Sixth State to Enact Law Regulating Earned Wage Access Services

Goodwin on

Arkansas has become the sixth state (and the first in 2025) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more

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