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On August 8, a judge in the U.S. District Court for the District of Maryland granted in part and denied in part a motion to dismiss several claims against an earned wage access (EWA) provider, addressing whether its wage...more
On July 8, the governor of Connecticut signed into law SB 1396 to amend the licensing statute for small loan companies and to add a regulatory framework for providers of “earned but unpaid wage or salary income advance.”...more
Connecticut has enacted a law (the amendment) amending the state’s existing small loan act (the act). In this alert, we focus on the amendment’s application of the act to “earned but unpaid wage or salary income advances”...more
The Arkansas legislature recently passed House Bill 1517, which creates an earned wage access law in the state. It will be one of the relatively few such laws in the country. One interesting question is whether the law...more
Louisiana has enacted a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more
Earned Wage Access (EWA) lets employees access wages they've already earned, but haven't yet been paid, typically through an app or digital service. For workers, this can mean avoiding payday loans or overdraft fees....more
Louisiana and Connecticut recently passed legislation establishing regulatory frameworks for earned wage access (EWA) providers. Connecticut’s SB 5140 passed the legislature on June 4 and awaits Governor Ned Lamont’s...more
Connecticut and Louisiana are poised to become the latest states to enact earned wage access (EWA) laws, as bills await signatures from Connecticut Gov. Ned Lamont and Louisiana Gov. Jeff Landry. The Connecticut bill passed...more
On May 25, the Maryland General Assembly chaptered HB 1294 and affirmatively subjected earned wage access products to the Maryland consumer credit and licensing provisions. The law requires companies that offer earned wage...more
On May 28, Maryland Governor Wes Moore signed House Bill 1294 into law, establishing a comprehensive regulatory framework for Earned Wage Access (EWA) providers operating in the state. Effective October 1, the new law...more
Indiana and Maryland join seven other states in enacting laws that specifically regulate earned wage access (EWA) providers. EWA is an on-demand payment product that allows workers to access their wages as they are...more
Maryland has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more
During the first Trump Administration, in response to federal financial agencies adopting a deregulatory approach, several states became more active in the enforcement of consumer financial statutes and regulations to fill...more
On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage...more
Indiana has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more
While uncertainty continued to loom over the CFPB, the states did not take a spring break. Instead, we saw an eye-popping settlement from NY DFS involving BSA/AML claims. And both republican and democratic AGs continued to...more
$23 billion. That’s how much Americans paid in late fees last year. When a payment is only a few days behind, late fees for credit cards, utilities, student loans, and rent pile up. And they have proliferated over the last...more
Just days apart, Arkansas and Utah enacted laws to regulate providers of earned wage access (“EWA”) services, joining the handful of states that have enacted legislation to regulate these products since 2022. Arkansas House...more
On April 14, the Attorney General (AG) for the State of New York filed two complaints in the New York State Supreme Court, alleging two earned wage access (EWA) providers violated civil and criminal usury provisions, as well...more
On April 14, New York Attorney General Letitia James announced two separate lawsuits against earned wage access providers—one against a company that issues advances directly to consumers, and another targeting a provider that...more
On April 7, an earned wage access (EWA) provider filed a complaint seeking declaratory relief against the New York Office of the Attorney General (OAG) in U.S. SDNY. The plaintiff requested relief from the OAG’s enforcement...more
Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more
On March 25, the governor of Utah signed into law HB 279, titled the “Earned Wage Access Services Act,” (the “Act”), which establishes regulations for earned wage access services that involve the payment of funds to consumers...more