News & Analysis as of

Earned Wage Access Truth in Lending Act (TILA) Loans

Sheppard Mullin Richter & Hampton LLP

District Court Allows Federal TILA and Maryland Consumer Loan Law Claims to Move Forward Against Earned Wage Access Provider

On August 8, the U.S. District Court for the District of Maryland issued an opinion partially granting an earned wage access (EWA) provider’s motion to dismiss that challenged whether the company operated as an unlicensed...more

Orrick, Herrington & Sutcliffe LLP

District court permits Maryland lending law and TILA claims to proceed against earned wage access provider

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

Ballard Spahr LLP

CFPB files and prosecutes yet another enforcement lawsuit using funds obtained in violation of the CFPB’s enabling statute...

Ballard Spahr LLP on

The Introduction to the Complaint which was filed by the CFPB on May 17, 2024 against Solo Funding, Inc. in the United States District Court for the Central District of California – Western Division Los Angeles (Judge R. Gary...more

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....more

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...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

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