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Advisory Opinions Truth in Lending Act (TILA) Consumer Financial Products

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is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

Orrick, Herrington & Sutcliffe LLP

CFPB rescinds previous opinion regarding how one EWA product was not a “loan”

On January 15, the CFPB issued an advisory opinion rescinding its 2020 advisory opinion on earned wage access (EWA) products. As previously covered by InfoBytes, the CFPB’s 2020 advisory opinion stated that a certain EWA...more

Troutman Pepper Locke

CFPB Rescinds 2020 Advisory Opinion on Earned Wage Access Products

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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

Ballard Spahr LLP

CFPB comments on California proposal to supervise providers of earned wage access products

Ballard Spahr LLP on

The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances”...more

Goodwin

CFPB Affirms Regulation Z Does Not Apply To Non-Recourse Earned Wage Access

Goodwin on

Recently, the Consumer Financial Protection Bureau (CFPB) issued an order accepting into the CFPB’s compliance assistance sandbox an earned wage access (EWA) program where participating employees are not obligated to repay...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

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