References and Supporting Documentation
EWA Done Right is compliant, responsible, and transparent and has the following five critical elements:
1. EMPLOYER-funded EWA program.
2. Data ACCURACY in EWA calculations.
3. TRANSPARENT and capped EWA fees.
4. PAYROLL DEDUCTION of EWA within the current pay cycle.
5. INSTANT FUNDING to the employee’s account of CHOICE.
Federal and state regulations and laws support these five EWA elements as outlined below.
Federal
12/09/20 – Consumer Financial Protection Bureau (CFPB): Advisory Opinion: Truth in Lending (Regulation Z); Earned Wage Access Programs
01/18/22 – CFPB: Seth Frotman, Acting General Counsel CFPB Letter
11/22/16 – CFPB: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z)
03/2023 – Department of the Treasury: 2022 Greenbook
03/08/23 – U.S. Government Accountability Office (GAO) Report – Financial Technology: Products Have Benefits and Risks to Underserved Consumers, and Regulatory Clarity Is Needed
State
02/11/22 – California Department of Financial Protections and Innovation (DFPI): Opinion Letter
Q1 2023 – CA DFPI: EWA Data Findings
03/2023 – CA DFPI: ISOR PRO 01-21
08/01/23 – Maryland Office of Financial Regulation (OFR): Consumer Advisory: Understanding Earned Wage Access Products
07/15/23 – Kansas Office of the State Bank Commissioner (OSBC): Request for Interpretative Opinion – FlexWage Solutions LLC
Other
09/2021 – Conference of State Bank Supervisors (CSBS): Model Money Transmission Modernization Act
Articles
08/25/23 – FlexWage Blog – Data Accuracy Differentiates EWA From Payday Loans
11/04/22 – FlexWage Blog – Constructive Receipt and Earned Wage Access
10/25/22 – FlexWage Blog – To Deduct Or Not To Deduct — The Facts About EWA Payroll Deductions
Patent
10/05/10 – FlexWage Patent Filed – System and method of intra-cycle payment of accrued employee wages
EWA Done Right
FlexWage delivers “EWA Done Right” because it offers the most compliant, responsible, and transparent Earned Wage Access (EWA) solution.
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