CFPB Releases Advisory Opinion Finding that Earned Wage Access Programs, When Structured Properly, Are Not Credit Under TILA and Regulation Z
By EsqSocial Corporation 31/12/20
On November 30, 2020, the Consumer Financial Protection Bureau released an advisory opinion concerning earned wage access ("EWA") products. The opinion was released as a sort of "launch day bonus" for the release of the Bureau's Final Advisory Opinions Policy and accompanying website page. The Bureau addressed whether EWA providers are offering or extending credit within the scope of Regulation Z. The Bureau determined that "Covered EWA Programs" do not involve the offering or extension of...
By: Hudson Cook, LLP