2.24.2025

OK: Testimony in Support of OK HB 2086

TO: Oklahoma House Business Committee
FROM: Ashley Urisman, Director, State Government Affairs, American Fintech Council (AFC)
DATE: February 24, 2025
SUBJECT: House Bill 2086

Position: Support.

Testimony:

Thank you Chair Banning, Vice-Chair Lay, and members of the House Business Committee for allowing me to submit testimony in support of HB 2086. My name is Ashley Urisman, I am director of State Government Affairs for the American Fintech Council (AFC).

AFC is the premier trade association representing the largest financial technology (Fintech) companies, including the biggest providers and largest number of Earned Wage Access (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.

EWA is not a loan and should not be regulated as such. As a distinct financial product, EWA must be governed by distinct regulations. This bill shapes a regulatory framework for companies to safely and responsibly offer EWA in Oklahoma. EWA is an innovative financial tool that empowers workers to access their wages in a way that best fits their lifestyle rather than keeping them tethered to arbitrary payroll cycles. Users can opt to access EWA through their employers, as stand-alone products, or as part of a subscription.

Oklahoma Workers are already reaping the benefits of EWA services. AFC member companies providing EWA have served more than 115,000 users and more than 1,000 employers across Oklahoma offer EWA as a benefit.

To ensure that EWA providers safely and effectively serve consumers, AFC has established clear standards on what constitutes responsible EWA. Our standards require

• A voluntary no-cost option be made available for all users;
• Strong fee disclosures represented in a clear and transparent manner;
• No underwriting or credit checks and
• Ability for users to cancel the EWA service at any time, meaning it does not have to be repaid.

The provisions of HB 2086 reflect those standards, and we thank you for your nuanced and thoughtful approach to regulating this industry.

Establishing the regulatory framework enumerated in HB 2086 will provide a critical financial choice for Oklahoma workers and allow responsible EWA services to flourish in this state. This bill will help workers access their pay by giving EWA providers a clear and functional regulatory path that recognizes the nuances of the service.

In closing, I applaud the Oklahoma legislature for taking up this issue in a timely manner and seeking a pragmatic solution to regulation. I thank you again for the opportunity to offer my support for this bill and can be reached to address any questions you may have via email at ashley@fintechcouncil.org

About the American Fintech Council: The mission of the American Fintech Council is to promote an innovative, responsible, inclusive, customer-centric financial system. You can learn more at www.fintechcouncil.org.