CFPB Proposal on Worker Pay Advance Disclosures Left Undone (1)

The Consumer Financial Protection Bureau withdrew guidance from President-elect Donald Trump’s first term limiting fee disclosures for a certain type of product giving workers early access to their pay, but the agency remained silent on a more recent, broader proposal treating “tips,” expediting, and other fees as finance charges.

The CFPB’s 2020 advisory opinion was insufficient because it applied only to one, unnamed company partnering with employers to offer workers an advance on their paychecks ahead of payday, and it contained an incomplete analysis of whether the advances qualified as credit, according to a Wednesday filing in the Federal Register. ...