Earned wage access (EWA)

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CFPB Advisory Opinion Analyzes Whether EWA Is Credit Under TILA and Regulation Z

The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion (AO), rescinding its 2024 proposed interpretive rule and clarifying the regulatory treatment of certain earned wage access (EWA) services. In the AO, the CFPB analyzes whether nonrecourse EWA services are subject to the Truth in Lending Act (TILA) and its implementing Regulation Z and confirms that certain employer-partnered EWA services are not “credit” under that …

Cooley December 23, 2025December 23, 2025

California DFPI Issues Annual Report Detailing Key Consumer Protection Accomplishments

On May 29, 2025, the California Department of Financial Protection and Innovation (DFPI) issued its annual report highlighting its activities and accomplishments in 2024 under the California Consumer Financial Protection Law (CCFPL). The DFPI reported that it issued regulations with new registration requirements for providers of earned wage access products, private postsecondary education financing, debt settlement services and student debt relief services – all of …

Cooley July 31, 2025September 11, 2025

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