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ARTICLE · 10 SEPTEMBER 2024

CFPB Proposes Interpretive Rule For Earned Wage Access Products

Greenberg Traurig
Greenberg Traurig
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On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Interpretive Rule and Request for Comment (Proposed Rule) addressing credit products in the paycheck advance...

United StatesFinance and Banking
Go-To Guide:
  • CFPB's proposed interpretive rule would classify earned wage access products as consumer "credit" under the Truth in Lending Act (TILA) and its implementing Regulation Z.
  • Under the proposal, expedited delivery fees and voluntary "tips" consumers pay related to earned wage access products would constitute "finance charges" under TILA and Regulation Z.
  • If the proposed rule takes effect, earned wage access providers operating in the United States would be impacted and subject to federal regulatory disclosure requirements.
  • The proposed interpretive rule intends to replace the CFPB's 2020 advisory opinion on earned wage access programs.

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