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ARTICLE · 13 AUGUST 2024

CFPB's Proposed Interpretive Rule On Earned Wage Access Products

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On Thursday, July 18, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule (Rule) that would define Earned Wage...

United StatesConsumer Protection
Benjamin Saul
Benjamin Saul
Andrew Owens
Andrew Owens
Vito Arethusa
Vito Arethusa
Tarrian Ellis
Tarrian Ellis

On Thursday, July 18, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule (Rule) that would define Earned Wage Access (EWA) products as credit. Specifically, the Rule intends to regulate earned wage access products, including "earned wage advances" and "earned wage access," as loans subject to Regulation Z and the Truth in Lending Act (TILA).1 The Rule would not impose any regulations or obligations separate from the provisions of Regulation Z and the TILA. The Rule is meant to replace an advisory opinion previously issued by the CFPB in November 2020 in which the CFPB found that some EWA products do not involve the offering of credit under Regulation Z and the TILA.2

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