The CFPB has issued an approval order through its Compliance Assistance Sandbox Policy (CAS Policy) to Payactiv in connection with its earned wage access (EWA) program.

The approval order confirms that Payactiv’s EWA program described in the order does not involve the offering or extension of “credit” as defined by section 1026.2(a)(14) of Regulation Z, and therefore, Payactiv has a safe harbor from liability under TILA and Regulation Z in connection with the specified EWA program. … Continue Reading