CFPB advisory opinion: earned wage access is not credit under TILA

Consumer Financial Protection Bureau issued Advisory opinion on December 22, 2025.

Primary

Consumer Financial Protection Bureau

Structure

Advisory opinion

Date

December 22, 2025

Sub-sector

Payments

CFPB formally determined covered EWA products are not credit under TILA, rescinding 2024 proposed rule; major win for EWA providers reducing compliance burden.

Primary company

Consumer Financial Protection Bureau

Counterparty

Not disclosed

Amount

Not disclosed

Event date

December 22, 2025

Sub-sector

Payments

HQ

Not disclosed

Structure

Advisory opinion

Source published

December 23, 2025

Publisher

American Banker

Source: americanbanker.com