"Simply put, EWA is not a loan, and should not be regulated as such. It bears no hallmarks of a traditional lending product – it offers a no-cost option and is a non-recourse tool providing millions of Americans with safe, convenient access to wages they have already earned. The Consumer Financial Protection Bureau (CFPB) came to this conclusion nearly four years ago, which allowed a host of responsible innovators to offer additional financial flexibility to consumers who may otherwise be pushed to predatory financial products like payday loans. It is these exact consumers – who are underbanked or have little to no credit history – that will be most harmed by efforts to reclassify EWA. AFC strongly objects to any legal, legislative, or regulatory action that seeks to erroneously classify EWA as a loan product and limit access to this safe, innovative financial product for the consumers who need it the most."