ICBA Letter to the CFPB on the Proposed Interpretive Rule on Earned Wage Access Products

ICBA commented on the Consumer Financial Protection Bureau’s proposed interpretive rule on EWA products. ICBA said it appreciated the Bureau’s intention of curbing costly EWA products but ICBA believes the Bureau is too broad in defining “debt,” which is not in accord with its 2020 advisory opinion of EWA products.