This document summarizes the key points of the Innovative Payments Association's (IPA) comment letter on the California Department of Financial Protection and Innovation's (DFPI) proposed rulemaking for Earned Wage Access (EWA) providers.
Main Concerns
The IPA emphasizes that employer-based EWA models differ from direct-to-consumer models and shouldn't be treated as loans. They outline the reasons for this distinction:
The IPA highlights the advantages EWA products offer consumers:
The IPA encourages the DFPI to consider the feedback from industry stakeholders and refine the proposed rulemaking to ensure it protects consumers without hindering access to valuable EWA services.
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