What the CFPB said—and why it matters
Published in the Federal Register on December 23, 2025, the opinion defines “Covered EWA” programs and confirms that optional expedited delivery fees and voluntary tips are generally not treated as finance charges under Regulation Z when the model meets the criteria, while formally withdrawing a 2024 proposal that leaned toward treating many EWA models as credit.
Legal analysts note the Bureau’s emphasis on repayment via payroll deduction, access capped at verified earned wages, non‑recourse to workers if payroll shortfalls occur, and no credit underwriting—a shift back toward the CFPB’s 2020 view and away from the 2024 interpretive stance.
To dig deeper, visit the original article on the Thomson Reuters blog.