In response to request, AFC letter to D.C. Department of Insurance, Securities, and Banking (DISB) emphasizes the importance of preserving worker access to earned wages through a bespoke, transparent, and responsible regulatory framework

Washington, D.C. (February 2, 2026) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies, innovative banks, and the largest number of leading earned wage access (EWA) providers, submitted a letter to the District of Columbia Department of Insurance, Securities, and Banking (DISB) in response to their Request for Public Comment regarding the regulation of Earned Wage Access (EWA) services in the District. The letter highlights the critical importance of a regulatory framework that recognizes EWA as a distinct, financial product safely utilized by thousands of D.C. workers.

“Earned Wage Access is a vital tool for employees managing their expenses between arbitrary pay periods, especially as the affordability crisis continues to harm D.C. families,” said Phil Goldfeder, CEO of the American Fintech Council. “A thoughtful, tailored regulatory approach recognizes the unique structure of Earned Wage Access, encourages responsible innovation, and ensures that workers have reliable, low-risk options to meet short-term financial needs.”

In their letter, AFC urged a registration-based framework in D.C. tailored to EWA’s unique structure, ensuring full consumer transparency, that recognizes the realities of modern pay practices and supports workers’ ability to access compensation they have already earned in a safe, transparent, and responsible manner. EWA addresses short-term cash liquidity challenges that many workers experience between arbitrary pay periods, particularly when faced with unexpected or non-discretionary expenses.

EWA serves as an alternative to high-cost predatory loans and the AFC letter warns that treating EWA as a loan would restrict access, reduce competition, and push workers toward higher-cost, higher risk alternatives, while proper classification preserves responsible innovation and safe, affordable access. The letter also emphasizes the value of flexible, transparent fees, including guaranteed no-cost options to protect consumer choice.

“Clear, tailored rules are critical for ensuring D.C. residents can safely access the wages they have already earned,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “By recognizing Earned Wage Access as a distinct, financial service, the District can provide transparency, protect workers, and maintain access to wage-based liquidity without pushing residents toward high-cost, high risk alternatives.”

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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