The Evolving Landscape of Earned Wage Access Regulation — The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for Innovative Consumer Financial Products; Part Two: Earned Wage Access
Consumer Finance Monitor Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for Innovative Consumer Financial Products; Part One: Buy-Now, Pay-Later
Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — Payments Pros – The Payments Law Podcast
Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — The Consumer Finance Podcast
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
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
Indiana and Maryland became the most recent states to enact legislation regulating earned wage access (EWA) services, with Indiana passing House Enrolled Act 1125 on May 6, and Maryland passing House Bill 1294 on May 20....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 29, the DFPI released its 2024 Annual Report of Activity under the California Consumer Financial Protection Law (CCFPL), highlighting regulatory activity, investigations, and public actions taken under the CCFPL....more
A new Maryland law deems certain earned wage access (EWA) services to be loans. It then subjects those EWA services to the Maryland Consumer Loan Law and other consumer credit provisions, restricts the acceptance of tips by...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
On May 27, 2025, Maryland enacted first-of-its-kind earned wage access (EWA) legislation to ensure Maryland workers are able to retain continued access to this valuable employee benefit. This landmark legislation follows...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 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...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