Payactiv, which as the first EWA provider began an EWA program about 13 years ago, partners with employers to offer their employees EWA. We first discuss what EWA is, the structure of the employer model used by Payactiv and other EWA providers, and how employers participate in and employees access their wages in the employer model. We next look at the structure of direct consumer advance EWA products, the fee structures of employer model and direct consumer advance products, employee usage and benefits of EWA, the CFPB’s advisory opinion on EWA, Payactiv’s participation in the CFPB’s sandbox program, and tax issues raised by EWA. We conclude with a discussion of federal and state regulatory activity directed at EWA and the future outlook for EWA.

Alan Kaplinsky, Senior Counsel in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.