CO: Testimony in Opposition of CO HB 25-1020

TO: Colorado General Assembly Committee on Finance
FROM: Ashley Urisman, Director, State Government Affairs, American Fintech Council (AFC)
DATE: February 24, 2025
SUBJECT: House Bill 25-1020

Position: Oppose.

Testimony:

Thank you Chair Lindstedt and members of the Finance Committee. My name is Ashley Urisman, I am director of State Government Affairs for the American Fintech Council (AFC). While we appreciate the work that has gone into this bill, and support the implementation of a regulatory framework for Earned Wage Access (EWA) in the Centennial State, we are opposing HB 1020 today. Our understanding is there are several amendments pending to this bill we have not seen, and we cannot support a bill the content of which we have not reviewed. We want to ensure that any regulatory regime established for EWA services allows responsible providers to serve users without limiting workers’ access to this vital service.

AFC is the premier trade association representing the biggest providers and largest number of EWA companies. Our mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. As a standards-based association, AFC has established parameters for what constitutes a responsible EWA service. EWA is not a loan and should not be regulated as such. As a distinct financial product, EWA must have distinct regulations. Our standards require that:

• A voluntary no-cost option be made available for all users;

• Fees are disclosed clearly and transparently;

• No underwriting or credit checks are required for customers to use the service;

• The ability for users to cancel the EWA service at any time, meaning it does not have to be repaid.

AFC and our members look forward to further collaborating with the Colorado legislature to establish a regulatory framework that mutually serves both Colorado workers and responsible EWA providers. Thank you and I am happy to take any questions you may have.

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