Overview
- An advisory opinion published December 23 defines a narrow class of “Covered EWA” that falls outside Truth in Lending Act coverage.
- To qualify, advances must be limited to verified earned wages, repaid solely through employer payroll, offered with clear no‑recourse notices, and provided without assessing individual creditworthiness.
- For Covered EWA, expedited delivery fees and voluntary tips generally are not finance charges when consumers have a reasonable no‑fee option.
- The Bureau cautions that fees or tips may be treated as finance charges if providers make no‑fee or no‑tip choices difficult to use.
- The CFPB withdrew its earlier proposal to classify all EWA as credit and stressed that the opinion does not resolve the status of EWA models outside the Covered EWA definition.