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Putting Earned Wage Access in its Place: A Guide for Employers

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In December 2023, the Consumer Financial Protection Bureau (CFPB) announced plans to outline how consumer lending laws interact with earned wage access (EWA) programs. These programs have grown in popularity as a solution for employees living paycheck to paycheck, offering early access to earned wages and, in theory, helping to dodge financial penalties like late fees and negative impacts on credit scores.

However, the landscape of EWA solutions is complex, marked by varied terms, conditions, and fees that are not always clear to employees or employers. Moreover, evidence suggests that these solutions are often used like painkillers, leading

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