News & Analysis as of

Truth in Lending Act (TILA) Short-Term Loans

Morrison & Foerster LLP

Earned Wage Access Products would be “Credit” under CFPB Proposed Interpretive Rule

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more

Foley & Lardner LLP

Think Twice Before Making Payroll Advances to Employees

Foley & Lardner LLP on

It can be difficult to turn down an employee who asks for an advance on their earnings. However, there are lots of reasons for companies to think twice before making payroll advances to employees....more

Morrison & Foerster LLP

Short-Term Lenders Face Costly Path To Compliance

On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more

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