“The recently issued report by the Center for Responsible Lending (CRL) demonstrates a complete misunderstanding and mischaracterization of the Earned Wage Access (EWA) industry and depends on improper interpretations of source materials to convey biased rhetoric to the detriment of consumers. The report relied on anecdotal information taken out of context and insufficient quantitative data for the magnitude of the authors’ claims. It does little to advance the dialogue about the proper regulatory framework for EWA providers in any pragmatic or useful manner.

The views and recommendations promulgated by CRL and further championed by NCLC are fruit from a poisoned tree, and not in the best interest of consumers. Therefore, the findings should be viewed with caution by policymakers, regulators, and other researchers. It is my sincere hope that AFC can work constructively with consumer advocates to ensure the development of sound and data-driven policy recommendations that benefit consumers.

The AFC and its members believe in robust consumer protections and meaningful discussions regarding the proper regulatory frameworks for innovative financial products and services. In this vein, we welcome all stakeholders and actively pursue opportunities to collaborate and learn from individuals that hold differing views on prudent regulation for the modern financial services industry. We also want to avoid unintended outcomes of improperly devised and overly broad statutory definitions and recommendations that not only fail to address real consumer needs but also could result in consumers being deprived of the benefits of EWA and driven back to predatory and harmful alternatives.”