Earned Wage Access: Where Innovation Meets Oversight

Session 3: IPA Compliance Boot Cam

Earned Wage Access (EWA) has quickly become one of the most talked-about tools in modern payroll and financial wellness programs. By allowing workers to access wages they’ve already earned before the company’s official payday, EWA aims to bridge short-term liquidity gaps without relying on high-cost credit. But as adoption grows, so too does regulatory scrutiny, and clarity has been anything but consistent.

In this session at the IPA’s Compliance Boot Camp, Eli Rosenberg of Baird Holm LLP will provide a comprehensive overview of how federal and state regulators are addressing EWA today. From differing definitions of what constitutes “credit” to conflicting advisory opinions, Rosenberg will break down what compliance professionals need to know to stay on solid footing.

Why EWA Matters Now

The regulatory landscape for EWA has shifted significantly in the past year. The Consumer Financial Protection Bureau’s (CFPB) 2020 advisory opinion initially affirmed that EWA was not credit, but subsequent actions, including a revocation in early 2025, have left providers in a state of uncertainty. Meanwhile, several states have introduced frameworks to govern EWA, adding another layer of complexity for both providers and employers.

Key session topics:

• Overview of EWA models and how they differ in structure and risk
• Federal activity and the evolving stance of the CFPB
• State-level laws and proposed legislation shaping the future of EWA
• Compliance best practices for providers and payroll partners
• How to navigate legal ambiguity while maintaining consumer trust
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Whether you’re directly offering EWA services or partnering with vendors that do, this session will give you the insight needed to evaluate your compliance posture and anticipate future challenges.

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The IPA’s Compliance Boot Camp  in Chicago on Sept. 11 offers a unique opportunity to dive deep into the latest regulations and trends. From hot topics like Open Banking and Earned Wage Access to the legal implications of AI and serving cannabis businesses, this one-day event is packed with insightful sessions led by industry experts. Eligible for up to 7 CLE credits in Illinois, Georgia, Florida, New York, and Texas, the Boot Camp provides both practical knowledge and professional development. Don’t miss this chance to gain the insights you need to thrive in today’s dynamic market. Register now.