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IPA News

Innovative Payments Association Applauds CFPB for Clarifying Earned Wage Access is a Non-Credit Product

12/22/2025

 
IPA applauds the CFPB for clarifying earned wage access is not credit, protecting workers’ access to earned wages while supporting innovation.

The Innovative Payments Association (IPA) praised the Consumer Financial Protection Bureau (CFPB) for issuing today’s Advisory Opinion (AO) on Earned Wage Access (EWA). The AO delivers much-needed clarity on the fundamental nature of EWA products, how workers use them, and how federal law applies to them. The CFPB acknowledged that properly tailored EWA programs are not credit products.

“This clear statement from the CFPB is a win for workers, their employers, and EWA innovators alike,” said Brian Tate, IPA President and CEO. “We thank Acting Director Vought and the CFPB for its common-sense approach to EWA. They have reaffirmed what millions of American workers already understand. EWA products are not loans because their wages are owed to them, and EWA products do not share characteristics with credit products. This clarification ensures that American workers can continue to safely access their earned wages without being pushed toward higher-cost alternatives.”

The CFPB’s EWA Advisory Opinion represents an important milestone for millions of American workers and the businesses that serve them. By recognizing that EWA allows employees to access wages they have already earned, the Bureau has affirmed a common-sense approach that protects consumers while supporting innovation and financial inclusion.

EWA products provide employees with the ability to access a portion of their earned income before payday, offering a responsible alternative to payday loans, overdraft fees, and other costly financial products. The CFPB’s recognition validates what industry leaders, bipartisan policymakers, and consumer advocates have long understood: that earned wage access is an income-smoothing tool, not a loan. In short, EWA provides consumers with a direct way to manage unexpected expenses by using their already-earned wages. Since paydays and bills don’t always align, EWA gives workers a crucial tool to manage their finances.

Since 2019, the IPA has been home to pioneering EWA providers who have worked diligently to inform regulators about the fundamental characteristics and profound benefits of earned wage access. “This clarification would not have been possible without the tireless dedication of our IPA members,” Tate emphasized. “Their efforts have not only helped provide American workers with crucial liquidity but have also saved them from millions of dollars in fees, truly making a contribution to workers’ financial wellness.”

Tate noted the AO was a first step in a new effort to ensure EWA products are regulated in a manner that protects workers and recognizes the fundamental characteristics of the products. “The IPA looks forward to working with regulators across the country and thanks pro-worker policymakers like Congressman Bryan Steil (R-WI) who continue to press for enduring statutory solutions.”

About the Innovative Payments Association (IPA)

The Innovative Payments Association is the leading voice of the electronic payments sector, representing companies offering prepaid, mobile, and emerging payment technologies to consumers, businesses, and governments. The IPA advocates for policies that promote financial inclusion, innovation, and consumer protection. Learn more at ipa.org or follow us on LinkedIn.

Innovative Payments Association President and CEO to Address CFPB Consumer Advisory Board on Earned Wage Access

12/10/2025

 
IPA’s Brian Tate testifies before the CFPB, underscoring earned wage access as a vital tool for consumers and calling for clearer regulatory guidance.

The Innovative Payments Association (IPA) announces that its President and CEO, Brian Tate, will testify before the Consumer Financial Protection Bureau’s (CFPB) Consumer Advisory Board today. Tate will provide insight into the current state of small-dollar financial products, emphasizing that earned wage access (EWA) is a tool that can support consumer financial stability.

The CFPB convened the session to examine how workers navigate liquidity challenges and the tools that help bridge timing gaps between pay cycles and financial obligations. Tate’s remarks underscore the essential role that EWA plays in giving consumers flexible, low-cost access to wages they have already earned, and the importance of restoring regulatory clarity that preserves this access.

“As more Americans face mismatches between when bills are due and when wages are paid, it is critical that they have access to safe and affordable financial tools,” Tate notes in his prepared testimony. “Earned wage access is not credit. It is a mechanism that allows individuals to access funds they have already earned, without creating debt or requiring a credit check.”

For nearly a decade, policymakers across parties and administrations have recognized that responsibly structured EWA programs are distinct from traditional credit. This testimony continues the IPA’s long record of leadership on the issue, building on years of engagement with regulators, Congress, and other stakeholders to ensure workers can safely access wages they have already earned.

As Tate highlights in his remarks, returning to straightforward guidance is critical to protecting access to EWA, supporting market innovation, and aligning regulatory oversight with how these products function in the real world.

Tate’s invitation to speak before the Advisory Board reflects IPA’s position as a leading voice for the evolving payments ecosystem and its ongoing commitment to advancing solutions that promote financial inclusion, encourage responsible innovation, and support consumer well-being.

About the Innovative Payments Association

The Innovative Payments Association (IPA) is the leading voice of the electronic payments industry, representing prepaid products, mobile wallets, and P2P payment technologies for consumers, businesses, and governments. IPA works to advance the adoption of electronic payments, promote financial inclusion, and advocate for the industry before legislative and regulatory bodies.

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  • About Us
    • Our Team
    • Board of Directors
    • Members
    • Partnerships
  • News & Events
    • News
    • 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
  • IPC 2027
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    • Hotel & Travel
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  • Join the IPA
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