In this special joint episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, co-leader of Troutman Pepper Locke's Consumer Financial Services Regulatory Practice, is joined by Keith Barnett and Jason Cover...more
As part of a flurry of last minute regulatory activity by the Biden administration’s Consumer Financial Protection Bureau (CFPB or Bureau), on January 15, the CFPB published an advisory opinion in the Federal Register...more
1/23/2025
/ Advisory Opinions ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Earned Wage Access ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payroll Deductions ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more
1/10/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Earned Wage Access ,
Financial Regulatory Reform ,
Financial Services Industry ,
New York ,
NYDFS ,
Proposed Legislation ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA) ,
Wages
On October 11, the Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on direct-to-consumer (i.e., non-employer offered) earned wage...more
10/24/2024
/ Banks ,
California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Office of Administrative Law Judges (OALJ) ,
Wage and Hour
In this special crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, and Chris Willis are joined by Jason Cover and Mark Furletti to discuss the Consumer Financial Protection...more
In this special crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, and Chris Willis are joined by Jason Cover and Mark Furletti to discuss the Consumer Financial Protection...more
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more
7/22/2024
/ Borrowers ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payday Loans ,
Proposed Rules ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
The California Department of Financial Protection and Innovation (DFPI) has once again modified its proposed rulemaking on earned wage access (EWA) products. As discussed here, this spring the Office of Administrative Law...more
On February 15, Massachusetts became the latest state to introduce legislation to regulate earned wage access (EWA) products and services. House Bill (HB) 4456 would create a new chapter to the Massachusetts Code explicitly...more
Recently, Arizona, Kentucky, and Hawaii have jumped on the bandwagon to regulate earned wage access (EWA) products and services. Arizona’s proposed bill makes clear that EWA services are not considered to be loans or money...more
2/2/2024
/ Arizona ,
Consumer Financial Products ,
Debt ,
Debt Collectors ,
Earned Wage Access ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Payday Loans ,
State and Local Government ,
Truth in Lending Act (TILA) ,
Unpaid Wages ,
Wage and Hour ,
Wages
On December 22, Montana Attorney General Austin Knudsen issued an opinion on whether Earned Wage Access (EWA) products constitute either “consumer loans” under Montana Code § 32-5-102(2)(a) or “deferred deposit loans” under §...more
As discussed here, on June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. Among other things, the bill: (1) raised the small loan limit from $15,000...more
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
7/13/2023
/ Consumer Financial Products ,
Credit Reports ,
Credit Scores ,
Earned Wage Access ,
Electronic Fund Transfer Act ,
Financial Services Industry ,
New Legislation ,
Payday Lending Rule ,
Popular ,
Regulatory Requirements ,
Wage and Hour ,
Wages
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