Fintech & Disguised Credit Archives

Comments on California DFPI Proposed Rules on Earned Wage Advances and Other Fintech Cash Advances

May 17, 2023

The Center for Responsible Lending, Consumer Federation of California, and National Consumer Law Center submitted comments to the Department of Financial Protection and Innovation’s (DFPI or Department) Proposed Regulations Under the California Consumer Financial Protection Law and the California Financing Law, California Deferred Deposit Transaction Law, and California Student LoanServicing Act, PRO 01-21. These comments…

Letter Opposing Nevada Earned Wage Advance Bill

May 9, 2023

NCLC and the Center for Responsible Lending oppose Nevada SB 290, an act relating to regulating earned wage advance services. The bill would break new ground by declaring that loans made through an “earned wage advance” app are not subject to Nevada’s statutes regulating credit, including advances that have no connection to employers. The bill…

Data on Earned Wage Advances and Fintech Payday Loan “Tips” Show High Costs for Low-Wage Workers

April 10, 2023

Data collected by the California Department of Financial Protection and Innovation (DFPI) on earned wage advances and other fintech payday loans show a cycle of repeat use and high costs typical of traditional payday loans. DFPI analyzed data covering nearly 6 million transactions by California consumers from seven companies. Three companies had a tip-based model…

Wharton Fintech Podcast: The Broken Credit Reporting System

March 8, 2021

In this episode of the Wharton Fintech Podcast, host Ryan Zauk sits down with Chi Chi Wu to discuss: The Fair Credit Reporting Act’s strengths and weaknesses The Big 3 Credit Bureaus…what’s broken, and how we can fix it Pros and cons of the new alternative data boom COVID’s devastating effects on individual credit Her…

NPR: Apple rolls out Apple Pay Later — a buy now, pay later service

March 30, 2023

Airing during NPR’s Morning Edition on Mar. 30, 2023, Lauren Saunders talks about Apple allowing some iPhone users to pay for purchases up to $1,000 in installments using Apple Pay Later. Buy now, pay later loans can be tricky, said Lauren Saunders, associate director at the National Consumer Law Center. “They can make things look…

Letter Analyzing Nevada Earned Wage Advance Bill

March 16, 2023

NCLC submitted a letter analyzing Nevada SB 290. The letter explains that the bill and other industry legislation would exempt various fintech payday loans from lending laws based on the disingenuous assertion that they are not loans.

California to Regulate Fintech Payday Loans

March 17, 2023

Junk fees, “tips” obscure APRs over 300% on earned wage advances, nonbank banking apps, and other fintech payday loans WASHINGTON – The California Department of Financial Protection and Innovation (DFPI) has proposed new regulations governing disguised fintech credit and released new data showing high costs for consumers who use earned wage advances and other fintech…

Testimony on Vermont H.87 Regarding Earned Wage Access Service Providers

March 13, 2023

Letter to the VT House Committee on Commerce and Economic Development re: H 87 An act relating to earned wage access service providers

Earned Wage Advances and Other Fintech Payday Loans: Workers Shouldn’t Pay to be Paid

April 20, 2023

Earned wage advances (EWA) are a form of payday loan. Fees appear small but can pile up in hidden ways and drain low wages. “Tip”-based fintech payday loans with no connection to wages can be even more expensive, 498% APR or higher, and can trigger overdraft and nonsufficient fund fees. Neither employer-based EWAs nor other…

Letter urging the Arizona Attorney General to Rescind Opinion Letter regarding Earned Wage Access Product

January 24, 2023

NCLC, along with the Center for Economic Integrity (CEI), the William E. Morris Institute for Justice, and Wildfire, sent a letter to the new Arizona Attorney General urging her to rescind Opinion Letter 122-005 (R22-011) regarding Earned Wage Access Products, which was adopted on December 18, 2022. The letter explains that the opinion is not…

Comments to the OCC on Supporting Responsible Innovation in the Federal Banking System

May 31, 2016

The National Consumer Law Center®, on behalf of its low income clients, Center for Responsible Lending, Empire Justice Center and U.S. Public Interest Research Group appreciate the opportunity to submit these comments in response to the Office of the Comptroller of the Currency’s request for comments on how to support responsible financial innovation. Our comments…

Comments to the OCC on "Exploring Special Purpose National Bank Charters for Fintech Companies"

January 17, 2017

The National Consumer Law Center (on behalf of its low-income clients) and Consumer Federation of America, Consumers Union, Main Street Alliance, and U.S. PIRG thank you for the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC’s) white paper on Exploring Special Purpose National Bank Charters for Fintech Companies. We appreciate…