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1 month ago | 
pymnts.com | Keith Barnett |Carlin McCrory
The article explores the growing reliance on Earned Wage Access (“EWA”) products in the financial market, where many individuals live paycheck-to-paycheck. EWA allows employees to access earned wages before payday, with products generally categorized into employer-integrated and direct-to-consumer models. The Consumer Financial Protection Bureau has shifted its stance on EWA, initially not considering it as credit under the Truth in Lending Act, but later suggesting they might be consumer le...
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1 month ago | 
openlegalblogarchive.org | Jason Cover |Carlin McCrory
In this episode of Payments Pros, Carlin McCrory introduces Jason Cover as a new co-host. Jason, a partner in Troutman Pepper Locke’s Consumer Financial Services practice, brings extensive knowledge in consumer lending and payments laws. He advises clients on electronic payments, online small business lending, electronic consents, contracts, disclosures, and recurring payment methods.
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2 months ago | 
openlegalblogarchive.org | Keith Barnett |Carlin McCrory
On April 7, DailyPay, LLC, an employer-integrated earned wage access (EWA) provider, filed a lawsuit against New York Attorney General Letitia James, seeking declaratory relief to prevent the enforcement of state and federal laws that the company argues do not apply to its business model.
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2 months ago | 
jdsupra.com | Keith Barnett |Carlin McCrory
On April 7, DailyPay, LLC, an employer-integrated earned wage access (EWA) provider, filed a lawsuit against New York Attorney General Letitia James, seeking declaratory relief to prevent the enforcement of state and federal laws that the company argues do not apply to its business model.
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2 months ago | 
law360.com | Keith Barnett |Caleb Rosenberg |Carlin McCrory
By Keith Barnett, Caleb Rosenberg and Carlin McCrory ( April 11, 2025, 5:20 PM EDT) -- On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement[1] with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law. This agreement followed the bank's reported loss of nearly $27 million for the quarter ending Sept. 30, 2024.... Law360 is on it, so you are, too.
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2 months ago | 
law360.co.uk | Keith Barnett |Caleb Rosenberg |Carlin McCrory
By Keith Barnett, Caleb Rosenberg and Carlin McCrory ( April 11, 2025, 5:20 PM EDT) -- On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement[1] with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law. This agreement followed the bank's reported loss of nearly $27 million for the quarter ending Sept. 30, 2024....
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2 months ago | 
jdsupra.com | Carlin McCrory |Ethan G. Ostroff
The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and U.S. territories, has raised significant concerns regarding the current draft of the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act.
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Mar 25, 2025 | 
jdsupra.com | Taylor Gess |James Kim |Carlin McCrory
On March 20, the Arkansas governor signed into law Arkansas Act 347, known as the Earned Wage Access Services Act. Sponsored by Representative David Ray (R) and Senator Ben Gilmore (R), this legislation aims to regulate earned wage access (EWA) providers. Notably, “providers” is defined to include a person engaged in the business of offering earned wage access, but not an employer that advances a portion of earned wages directly to employees or independent contractors.
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Mar 17, 2025 | 
openlegalblogarchive.org | James Kim |Carlin McCrory |Caleb Rosenberg |Taylor Gess
The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA) providers. Notably, “providers” is defined to include a person engaged in the business of offering earned wage access, but not an employer that advances a portion of earned wages directly to employees or independent contractors.
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Mar 17, 2025 | 
jdsupra.com | Taylor Gess |James Kim |Carlin McCrory
The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA) providers. Notably, “providers” is defined to include a person engaged in the business of offering earned wage access, but not an employer that advances a portion of earned wages directly to employees or independent contractors.
