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Expert Analysis

How CFPB Opinion Changes Earned Wage Access Definition

By Jennifer Crowder and John ReVeal ( April 15, 2026, 5:00 PM EDT) -- The Consumer Financial Protection Bureau recently issued an advisory opinion concluding that covered earned wage access, or EWA, is not credit for purposes of Regulation Z of the Truth in Lending Act, any fees associated with covered EWA would not be finance charges under Regulation Z, and expedited delivery fees and tips usually will not be finance charges for EWA that is not covered.[1]...

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