In January, PayrollOrg’s Government Relations Task Force commented in support of earned wage access (EWA) bills in Colorado, Indiana, New Mexico, Oregon, Vermont, and Washington. The bills include some common elements, including clear definitions, EWA provider licensing, consumer protections, and nonrecourse provisions.
Common Elements
Definitions. The definitions describe the services considered EWA and distinguish between EWA services and credit-based services. The definitions recognize the role of employers in early pay benefits.
EWA provider licensing. The bills identify specific procedures when applying for a license and explain state oversight. Each of the bills contains a list of information that EWA providers must include in license applications.
Consumer protections. Providers must create policies and procedures to answer user questions and complaints, fully disclose fees associated with user participation, provide a no-cost option to users, and allow users to opt out of the benefit later without penalty.
Nonrecourse provisions. Nonrecourse provisions place the responsibility for accurate early wage determinations on EWA providers. In employer-integrated programs, real-time payroll data is shared with providers to ensure accuracy.
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Alice P. Jacobsohn, Esq., is Director of Government Relations for PayrollOrg.
