IPA Urges CFPB to Modernize Prepaid Account Rules, Provide Greater Clarity for EWA

The Innovative Payments Association (IPA) has submitted a letter to the Consumer Financial Protection Bureau (CFPB) outlining recommendations to modernize regulations governing prepaid accounts and earned wage access (EWA). The letter responds to Executive Order 14405, which calls for streamlined regulation, reduced barriers to innovation, and greater collaboration between fintech companies, financial institutions, and regulators.

Modernizing Prepaid Account Rules

​The IPA is urging the CFPB to revisit the Prepaid Account Final Rule, which has been in effect since 2019. While supporting strong consumer protections, the IPA argues that the current framework creates unnecessary compliance burdens and puts prepaid products at a disadvantage compared with similar financial products.
The association recommends streamlining disclosure requirements and creating greater regulatory parity between prepaid and traditional debit accounts, particularly around access to credit and overdraft services.

Providing Clarity for Earned Wage Access

The IPA also calls for greater federal regulatory clarity for EWA. While the IPA supported the CFPB's December 2025 Advisory Opinion addressing certain EWA products, it believes the opinion does not adequately address the broader range of models operating in today's market.

The IPA recommends an updated framework that provides consistent treatment across EWA models, supports innovation and competition, and maintains appropriate consumer protections.

Download the letter for full information, including the IPA's detailed recommendations and supporting analysis.

Download Comment Letter