CFPB Exempts Most Worker Pay Advances From Loan Disclosures (1)

December 22, 2025, 4:25 PM UTCUpdated: December 22, 2025, 7:35 PM UTC

Financial technology companies with any connection to an employer’s payroll data don’t have to make full loan disclosures to customers seeking early access to their paycheck, the Consumer Financial Protection Bureau said.

Earned-wage access providers that either partner with employers or use payroll data to advance wages already accrued in direct-to-consumer offerings aren’t subject to loan disclosure requirements under the 1968 Truth in Lending Act, the CFPB determined in an advisory opinion set for publication Tuesday.

The opinion largely reinstates 2020 guidance the CFPB issued during the first Trump administration, but it expands the loan disclosure exemptions by also carving ...

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