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Rulemaking Process › Earned Wage Access

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is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

Ballard Spahr LLP

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

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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

CFPB Proposes Interpretive Rule Characterizing Earned Wage Access Products as Loans

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On July 18, the CFPB proposed a new interpretive rule that would characterize earned wage access (“EWA”) products as extensions of credit and subject to the Truth in Lending Act and Regulation Z. Under the interpretive...more

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