After reviewing what EWA is and the different models used for EWA programs, we discuss federal and state regulatory issues raised by such programs, the CFPB’s advisory opinion on such programs and the questions it raises, how a change in CFPB leadership under the Biden Administration could impact such programs, and the future of such programs. Ballard Spahr attorney Alan Kaplinsky hosts with Mr. Silverman and James Kim, co-leader of the firm’s Fintech and Payments Team.