SC: Joint Advocacy Letter to the South Carolina Legislature Committee on Labor, Commerce, and Industry in Support of S 700

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TO: The South Carolina Legislature Committee on Labor, Commerce, and Industry

FROM: Elizabeth Gorz, Chief Strategy Officer and Head of Legislative Affairs, American Fintech Council (AFC)

DATE:  April 30, 2024

SUBJECT: Senate Bill 700

Position: Support.

Re: Request for Passage of Earned Wage Access Legislation- S. 700

Dear Chairman Sandifer III and Vice-Chair Taliaferro West IV,

We the undersigned, representing the premier industry association and companies developing responsible innovations and sound public policy that improve the financial lives of consumers across the country, write to express our strong support for Senate Bill 700 (S. 700)and the Earned Wage Access (EWA) registration structure contained therein. We respectfully request your support for S. 700.

EWA is a new and innovative industry that empowers workers by allowing them to access the pay they have earned, on their schedule – without waiting until payday, giving workers the options they need to support their families and improve their financial lives. We believe that the bill, as passed by the South Carolina Legislature, properly balances responsible innovation with a pragmatic, consumer protected regulatory framework that fits the EWA industry.

S. 700 establishes clear standards for acceptable EWA services regulated under its registration regime in a manner that reflects the nuances and optionality of the EWA industry while also protecting consumers from irresponsible actors. Specifically, the bill’s provisions requiring strong fee disclosures represented in a clear and transparent manner; and the ability for users to cancel the EWA service at anytime present strong consumer protections for South Carolinians that will ensure they can continue to use EWA services in a safe and secure manner.

Establishing the regulatory framework enumerated in S. 700 will allow EWA services to flourish in South Carolina and help workers access the pay they are entitled to when needed. In fact, our data shows that approximately 500,000South Carolinians have used an EWA product, whether offered through their employers, directly through an app, or as part of a financial health subscription service.

Therefore, we respectfully request that you vote in favor of S. 700 and create a clear and effective registration structure for EWA providers that will ensure strong protections for South Carolina and help responsible EWA providers offer their services to the benefit of the residents across the state.

Sincerely,

Elizabeth Gorz

Chief Strategy Officer and Head of Legislative Affairs, American Fintech Council

Tara Rider

VP- Policy and Government Relations, Brigit

Colin Jones

General Counsel, Cleo

Joseph N. Garba

Head of External Affairs, Cross River

Ryan Naples

Director- Public Policy, DailyPay

Yvonne Chao

Director- Public Policy, EarnIn

Molly Jones

VP- Head of Public Policy, Payactiv

Kevin Lefton

US Head of Legal and Regulatory Affairs, Wagestream

Garth McAdam

General Counsel, ZayZoon