The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule stating that paycheck advance programs, also known as earned wage access and on-demand pay, offered to employees via employers and directly via FinTech apps are to be considered as "consumer loans," subject to the Truth in Lending Act.

The CFPB aims to ensure workers understand the costs and fees associated with these products, which have grown in popularity. These products allow workers to access their wages before payday, based on a fee.

According to the CFPB's analysis, the typical paycheck advance user pays fees amounting to a 109.5% annual percentage rate (APR), despite the service being marketed as "free" or "low cost." More than 7 million workers accessed around USD 22 billion through such products in 2022, with over 90% paying at least one fee.