In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These changes impose new compliance obligations for businesses offering EWA products to California consumers.

This GT Alert summarizes the regulation’s highlights.

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On Dec. 22, 2023, Montana Attorney General Austin Knudsen issued an opinion clarifying that certain Earned Wage Access products are not loans under either the Montana Consumer Loan Act or the Montana Deferred Deposit Loan Act.…

Continue Reading Montana Attorney General Confirms Certain Earned Wage Access Products Are Not Loans

On Aug. 1, 2023, the Maryland Office of Financial Regulation (OFR) published new guidance on Earned Wage Access (EWA) products, intending to provide clarity on how EWA products are viewed under Maryland law and requirements those offering EWA products should follow.

Continue reading the full GT Alert.

* Greenberg Traurig is not licensed to practice…

On June 15, 2023, Nevada Gov. Joe Lombardo signed SB 290, establishing the nation’s first state licensing regime for earned wage access (EWA) services provided to consumers in the state. Earned wage access allows employees to receive portions of their earned but unpaid income in advance to be repaid by the employees after being…