“We thank Commissioner Jorge Perez and the Connecticut Department of Banking for extending the No-Action period for companies offering Earned Wage Access (EWA) products through the end of the year. We appreciate the opportunity for additional time to allow us to engage in thoughtful and meaningful dialogue with the Department of Banking and legislative leaders regarding regulation of this innovative service and enactment of important consumer protections.

EWA is not credit and should not be regulated as such. EWA is a payroll innovation that enables workers to access wages they have already earned when they need it and serves as an important alternative to arbitrary pay periods and high-cost predatory options. EWA providers in our membership have served more than 150 thousand Connecticut families who deserve access to safe, reliable and transparent services as opposed to high priced predatory alternatives.

Responsible and affordable EWA companies are democratizing financial services and disrupting broken legacy systems that have historically put consumers at a disadvantage. As the trade association representing the largest EWA providers, AFC has worked tirelessly to promote and advocate for EWA industry best practices and consumer protections, including strong transparency and disclosures, non-recourse, no late fees or penalties, no debt collection, no credit reporting, no collection activity of any kind, and a requirement that a “no cost” option be offered to all EWA users.”