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
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
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 7, DailyPay, LLC, an employer-integrated earned wage access (EWA) provider, filed a lawsuit against New York Attorney General Letitia James, seeking declaratory relief to prevent the enforcement of state and federal...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
Utah has become the seventh state (and the second in 2025) to enact 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...more
The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA)...more
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
Last month, we discussed the California Department of Financial Protection and Innovation’s (DFPI) newly approved regulations for direct-to-consumer earned wage access (EWA) products. These regulations, approved by the Office...more
On October 11, California’s Office of Administrative Law (“OAL”) approved the Department of Financial Protection and Innovation’s (“DFPI’s”) registration rulemaking for providers of the following products...more
In recent years, earned wage access (EWA) – an innovative technology that enables workers to access their own, already earned wages without having to wait for payday – has rapidly become a table stakes employee benefit. By...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
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