CFB Proposes Interpretive Rule on Earned Wage Access

The Consumer Financial Protection Bureau (“CFPB”) yesterday announced a proposed interpretive rule likening earned wage access (“EWA”) products to consumer loans, requiring the disclosure of costs and fees. The interpretive rule, if finalized, would replace the CFPB’s 2020 Advisory Opinion on EWA products. The 2020 Advisory Opinion provided that certain EWA products were not “credit” under the Truth in Lending Act (“TILA”) or Regulation Z if all of several identified conditions were met, including that the products were administered through employers and were free to consumers… Read More