California DFPI Signs First Memoranda of Understanding with Earned Wage Access Companies
Troutman Sanders
FEBRUARY 17, 2021
For purposes of the federal Truth in Lending Act, the CFPB issued an advisory opinion in late 2020 determining that, if these arrangements contain certain characteristics, they do not involve a “credit” subject to Regulation Z. At least one company has obtained a CFPB approval order for its EWA offering.
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