Innovative Payments Association
  • About Us
    • Our Team
    • Board of Directors
    • Members
    • Partnerships
  • News & Events
    • Non-Member Newsletter
    • Newsroom
    • Events
    • Blog
    • Podcast
  • Member Resources
    • Glossaries & Reports
    • GRWG
    • Recordings
    • Government Update
    • State Legislative Tracker
    • Financial Crimes Investigators
  • Issues & Advocacy
    • Comment Letters
    • Payments Litigation
    • Current Issues >
      • Earned Wage Access
      • Fraud Prevention
      • Prepaid Rule
    • Ongoing Issues >
      • Arbitration
      • Artificial Intelligence
      • Banking as a Service
      • Brokered Deposits
      • CFPB
      • Covid Response
      • Durbin Amendment
      • FDIC & OCC
      • Privacy Legislation
      • Unclaimed Property
  • Join the IPA
    • IPA Wins
  • Boot Camp
Member Login   |   Join the IPA
Member Login   |   Join the IPA

 Comment Letters

EWA Regulation in California: IPA Pushes for Nuance

11/17/2023

0 Comments

 
The Innovative Payments Association (IPA) is urging California's Department of Financial Protection and Innovation (DFPI) to refine its proposed regulations for Earned Wage Access (EWA) providers. The IPA argues that the current draft lumps together all EWA products, potentially creating unnecessary burdens and misleading consumers.
Key Concerns:
  • One-size-fits-all approach: The IPA believes the proposal fails to acknowledge the diversity of EWA models. Not all EWA products function like loans.
  • Misleading consumer information: The current rules might confuse EWA fees with separate payroll card fees.
  • Unfair classification: The IPA argues that some EWA models shouldn't be classified as loans under California's Financing Law (CFL).
What the IPA Wants:
  • Recognition of EWA Model Variety: The DFPI should acknowledge that EWA products come in different forms, with some not resembling loans.
  • Clearer Fee Definitions: The rules should distinguish between EWA fees and payroll card fees to avoid misleading information.
  • Exemption for Non-Loan EWA Models: The IPA urges the DFPI to exempt certain EWA models from the CFL, reflecting their non-credit nature.

The IPA believes a more nuanced approach is essential for regulating EWA effectively and protecting consumers. They emphasize the importance of regulatory clarity for this relatively new financial tool.
Download Comment Letter
0 Comments

    Archives

    July 2025
    June 2025
    May 2025
    March 2025
    January 2025
    December 2024
    November 2024
    October 2024
    August 2024
    April 2024
    February 2024
    November 2023
    May 2023

    Categories

    All
    Bank Fintech
    Bank-Fintech
    Brokered Deposits
    CFPB
    Earned Wage Access
    EFT
    Prepaid

Contact Us   |   Member Resources

IPA

110 Chestnut Ridge Rd, Suite 111
Montvale, NJ 07645
(202) 548-7200
Save The Date 
Innovative Payments Conference​
April 29 - May 1, 2026 

IPA Info

Home
​​About Us
Advocacy
Newsroom​
Contact Us

IPA Resources

IPA News & Events
Payments Podcast
Blog​
​Events


Safe Shopping
Consumer Resources if You've Been Scammed
© COPYRIGHT 2025 ALL RIGHTS RESERVED. | Privacy Policy
  • About Us
    • Our Team
    • Board of Directors
    • Members
    • Partnerships
  • News & Events
    • Non-Member Newsletter
    • Newsroom
    • Events
    • Blog
    • Podcast
  • Member Resources
    • Glossaries & Reports
    • GRWG
    • Recordings
    • Government Update
    • State Legislative Tracker
    • Financial Crimes Investigators
  • Issues & Advocacy
    • Comment Letters
    • Payments Litigation
    • Current Issues >
      • Earned Wage Access
      • Fraud Prevention
      • Prepaid Rule
    • Ongoing Issues >
      • Arbitration
      • Artificial Intelligence
      • Banking as a Service
      • Brokered Deposits
      • CFPB
      • Covid Response
      • Durbin Amendment
      • FDIC & OCC
      • Privacy Legislation
      • Unclaimed Property
  • Join the IPA
    • IPA Wins
  • Boot Camp