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Regulation of the Wages-On-Demand Industry  


Author:  Stephen T. Middlebrook.; Tom Kierner.


Source: Volume 36, Number 03, March 2020 , pp.37-40(4)




Review of Banking & Financial Services

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Abstract: 

Wage advance products—also known as wages-on-demand, advance wage payment, earned income access, and wage-based or work-based advances—are popular with employees, but raise some novel legal issues for employers and providers. The authors describe how these products work, whether they involve an extension of credit, compliance with state wage and hour laws, and new state legislation that would regulate the industry.

Keywords: Wage Advance Products; Consumer Financial Protection Bureau (“CFPB”); California SB 472; New Jersey SB 866

Affiliations:  1: Womble Bond Dickinson (US); 2: Womble Bond Dickinson (US).

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