Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule

Episode notes

In this special crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, and Chris Willis are joined by Jason Cover and Mark Furletti to discuss the Consumer Financial Protection Bureau's (CFPB) proposed interpretive rule on earned wage access (EWA) products. EWA allows employees to access wages they have earned before payday, with two main models: employer-integrated and direct-to-consumer. The conversation explores the differences between EWA and payday lending, emphasizing that EWA typically does not involve finance charges or obligations to repay. The podcast explains the CFPB's proposed interpretive rule, which replaces the 2020 guidance that was more favorable to the industry. The new rule would classify EWA products as credit under the Truth in Lending Act (TILA), requiring additional disclosures. The discussion also covers the CFPB's stance on expedited funding fees and tips, which they argue should be considered finance charges. The group discusses the CFPB's approach, noting potential challenges and the lack of justification for the proposed rule.

Related episodes across the Index

Other episodes covering the same guests and topics, from across The B2B Podcast Index.

• Building Smart Businesses on WhatsApp - Peter Adolphs - AskMandlaNo Free Lunch With Greg Stewart · on Earned wage access79 / 100
• Embedded Finance and Earned Wage Access: How Payroll Is Redefining Financial WellnessThe Issuer Academy: Innovate. Scale. Impact · on Earned wage access75 / 100
• 2024 Election: What Does it Mean for Financial Services and Tech?Tech On Reg Podcast · on Earned wage access75 / 100
• Mary Wisniewski on Instant Payments: Why 24/7 Money Movement on the RTP® Network Is Reshaping Banking, Consumer Expectations, and Fintech InnovationPayments Nerds · on Earned wage access55 / 100
• The Holistic Care of Entrepreneurs with Jace MouseSavage to Sage · on Earned wage access54 / 100
• Matt Dicou, Co-Founder & CEO, ResetCredit Unions, Coffee & Conversations · on Earned wage access53 / 100

• Payments Compliance and the FTC's Focus on Subscription Practices69 / 100
• Regulating Prediction Markets: Federal Oversight, State Authority, and the Road Ahead66 / 100
• The Debanking Debate: Regulators, Risk, and Reality for Payments72 / 100
• Point-of-Sale Finance Series: Evolving Collection Rules Impacting Creditors65 / 100
• Point-of-Sale Finance Series: Fair Lending Risks at the Checkout Counter