A key issue for earned wage access (EWA) programs is whether they constitute “credit” for purposes of federal consumer financial protection laws such as TILA, ECOA, and the CFPA, or under state law.  The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals includes a proposal concerning how EWA programs should be

Rising interest rates and inflation are two key factors that are expected to create a more challenging business environment in 2022.  Based on his work at the intersection of technology and financial services, Todd shares his perspective on how this new environment is likely to impact providers of various types of consumer financial services, particularly

In a letter to three representatives of consumer advocacy groups, CFPB Acting General Counsel Seth Frotman indicated that due to “repeated reports of confusion” caused by the CFPB’s November 2020 advisory opinion (AO) on earned wage access (EWA) programs, he plans to recommend to Director Chopra “that the CFPB consider how to provide greater clarity