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Earned Wage Access Regulatory Requirements

Mayer Brown

Arkansas and Utah Enact Laws to Regulate Earned Wage Access Providers

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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

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

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

Goodwin on

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

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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – March 2025 # 3

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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

Utah Legislature Passes Earned Wage Access Services Act

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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

McGuireWoods LLP

Utah to Join Other States Enacting Legislation to Regulate Earned Wage Access

McGuireWoods LLP on

Upon signature by Gov. Spencer Cox, Utah will join five other states in enacting a law that specifically regulates earned wage access (EWA) providers as nonlenders....more

Ballard Spahr LLP

CFPB revokes EWA advisory opinion

Ballard Spahr LLP on

The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more

Troutman Pepper Locke

Registration Information Released for California DFPI’s Earned Wage Access Regulations

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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

Ballard Spahr LLP

California Finalizes Registration Requirements for Providers of Earned Wage Access, Other Financial Products and Services

Ballard Spahr LLP on

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

Sheppard Mullin Richter & Hampton LLP

Wisconsin Signs Earned Wage Access Bill into Law

On March 21, Wisconsin enacted into law Assembly Bill 574, positioning it as the third state, following Nevada and Missouri, to establish a comprehensive regulatory framework for earned wages access (EWA) services and...more

Payactiv

Consumer Protection Priorities in Earned Wage Access Legislation

Payactiv on

In recent years, earned wage access (EWA) – an innovative technology that enables workers to access their own, already earned wages without having to wait for payday – has rapidly become a table stakes employee benefit. By...more

Troutman Pepper Locke

Missouri Becomes Latest State to Establish Regulatory Framework for Earned Wage Access Products

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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

Troutman Pepper Locke

Nevada Passes Law Creating Licensing Requirements for Earned Wage Access Providers

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On June 15, Nevada Governor Joe Lombardo signed SB 290 into law, which imposes licensing, reporting, examination, and other substantive requirements on providers of earned wage access (EWA) products. Specifically, the...more

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