WASHINGTON, D.C. – The Consumer Financial Protection Bureau (Bureau) issued a compliance assistance sandbox (CAS) approval order to PayActiv regarding specific aspects of some of its earned wage access (EWA) products. EWA products allow employees access to their earned but unpaid wages prior to payday.
Issued under the from last year, a CAS approval offers an entity confronting regulatory uncertainty a “safe harbor” from liability under specified legal provisions. Entities are offered safe harbor for specified conduct that the Bureau finds compliant with those legal provisions, subject to good faith compliance with the terms of the approval. The CAS Policy implements the existing safe harbor approval mechanisms provided under the Electronic Fund Transfer Act, the Equal Credit Opportunity Act, or—as in this case—the Truth in Lending Act. The duration of the approval in this case is two years.
The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives. For more information, visit www.consumerfinance.gov.