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Consumer Financial Protection Bureau (CFPB) › Regulation Z › Wage and Hour

McGlinchey Stafford

The Earned Wage Access Boom: Sixteen States Propose Legislation to Regulate These Types of Products

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Since the beginning of 2025, sixteen states have proposed legislation to regulate earned wage access. These states would join Kansas, Missouri, Nevada, South Carolina, and Wisconsin, which have each enacted legislation to...more

Ballard Spahr LLP

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

Ballard Spahr LLP on

On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more

Troutman Pepper Locke

CFPB Says Earned Wage Access Products are Subject to the Truth in Lending Act

Troutman Pepper Locke on

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

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

Troutman Pepper Locke

CFPB Issues Letter Supporting California DFPI’s Proposed Classification of EWAs as Loans and Promises Guidance as to Federal...

Troutman Pepper Locke on

In March 2023, the California Department of Financial Protection and Innovation (DFPI) proposed new regulations under the California Financing Law that would update the definition of loan to include what it dubs as...more

Jenner & Block

Client Alert: Navigating the EWA Regulatory Landscape

Jenner & Block on

I. Introduction: EWA on the Precipice - The increasing use of earned wage access (“EWA”) by workers in the United States and around the world has helped to bring financial flexibility to many previously constrained by the...more

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

Goodwin

California’s Mini-CFPB Enters into Memorandums of Understanding with Earned Wage Access Fintech Companies

Goodwin on

In January 2021, the new California Department of Financial Protection and Innovation (DFPI) entered into memorandums of understanding (MOUs) with five earned wage access fintech companies so that these companies can continue...more

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