CFPB Issues Advisory Opinion on Earned Wage Access Programs
By EsqSocial Corporation 06/01/21
The CFPB recently issued an advisory opinion clarifying certain Earned Wage Access (EWA) programs do not involve an offer of “credit” under Regulation Z, which implements the Truth in Lending Act (TILA). This advisory opinion was issued concurrently with the CFPB’s finalization of its Advisory Opinion Policy, previously covered by WBK....
By: Weiner Brodsky Kider PC