The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances” to register with or obtain a license from the DFPI and comply with the fee and interest rate limits of the California Financing Law (CFL).… Continue Reading
earned wage
CFPB issues compliance assistance sandbox approval for earned wage access product
By Ballard CFS Group on
Posted in CFPB, Regulatory and Enforcement
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