News & Analysis as of

Payroll Deductions Financial Services Industry

Hudson Cook, LLP

Earned Wage Access - Now with Fees: A Low-Cost Credit Alternative or State Regulatory Minefield?

Hudson Cook, LLP on

We recently wrote about the Consumer Financial Protection Bureau's November 2020 advisory opinion regarding earned wage access (EWA) programs. In that opinion, the CFPB determined that earned wage access programs — when...more

Cooley LLP

Alert: Consumer Financial Protection Bureau Wades Into Earned Wage Access Space

Cooley LLP on

Two recent actions broadly supportive of employer-based programs, risks for certain wage deduction practices noted On-demand pay providers have become increasingly common employer-facilitated employee benefits in recent...more

McGuireWoods LLP

A Detailed Look At The CFPB’s Historic Approval of Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy

McGuireWoods LLP on

Last week, we reported that on December 30, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued compliance assistance sandbox (“CAS”) approval to Payactiv, Inc. (“Payactiv”) regarding specific aspects...more

Ballard Spahr LLP

CFPB issues compliance assistance sandbox approval for earned wage access product

Ballard Spahr LLP on

The CFPB has issued an approval order through its Compliance Assistance Sandbox Policy (CAS Policy) to Payactiv in connection with its earned wage access (EWA) program....more

Hudson Cook, LLP

CFPB Releases Advisory Opinion Finding that Earned Wage Access Programs, When Structured Properly, Are Not Credit Under TILA and...

Hudson Cook, LLP on

On November 30, 2020, the Consumer Financial Protection Bureau released an advisory opinion concerning earned wage access ("EWA") products. The opinion was released as a sort of "launch day bonus" for the release of the...more

McGuireWoods LLP

CFPB’s Fee-Free Model Requirement Set Forth In Its Wage Access Advisory Opinion Raises More Questions

McGuireWoods LLP on

In an earlier article, we provided an overview of the Consumer Financial Protection Bureau’s (“CFPB”) earned wage access (“EWA”) advisory opinion. In the opinion, the CFPB identified seven requirements that for a “Covered...more

Ballard Spahr LLP

CFPB finalizes advisory opinions policy and issues two advisory opinions

Ballard Spahr LLP on

The CFPB has issued its final Advisory Opinions Policy, which allows stakeholders to request interpretive guidance “to resolve regulatory uncertainty.” While advisory opinions (AO) may address uncertainty in both statutes...more

Womble Bond Dickinson

CFPB Issues Advisory Opinion on Earned Wage Access Programs

Womble Bond Dickinson on

CFPB issued an advisory opinion on Earned Wage Access (EWA) on Monday afternoon. We’ve written about earned wage access products before as well as state legislative initiatives to regulate them. The new federal guidance...more

Womble Bond Dickinson

New Jersey Bill Would Prohibit Certain Wages-on-Demand Services and Regulate Others

Womble Bond Dickinson on

In 2019, California was the first state to take a swing at explicitly regulating wages-on-demand services. The state senate considered a bill that would provide exemptions to payday lending, money transmission, and financing...more

Epstein Becker & Green

Federal Court’s Approval of Settlement in Litigation Over Expenses Charged to Brokers Offers Guidance on Settlement of Parallel...

Epstein Becker & Green on

On September 6, 2019, the U.S. District Court for the Northern District of California preliminarily approved a settlement in Harvey v. Morgan Stanley Smith Barney LLC. The significance of the result is two-fold. First,...more

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