Earned Wage Access Products Are Not Loans, According to the AG of Montana
CFPB Monitor
JANUARY 5, 2024
On December 22, 2023, the Attorney General of Montana released an opinion (the “Opinion”) concluding that certain earned wage access (EWA) products are not “consumer loans” or “deferred deposit loans” under Montana law and do not, therefore, require licensure by the Montana Division of Banking and Financial Institutions.
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