EARNED WAGE ACCESS: PEACE OF MIND FOR EMPLOYEES IN UNCERTAIN TIMES

BY Andy Songer

Channel Sales Manager
Green Dot Coporation

May 2024

In an era where personal financial stability is a growing and real concern among employees, the advent of Earned Wage Access (EWA) stands as a beacon of hope for individuals navigating the complexities of modern-day finances. This innovative financial solution has emerged as a lifeline for those living paycheck to paycheck, offering a bridge between earnings and expenses. In this article we will address and answer many of the concerns over the concept of Earned Wage Access, its mechanisms, benefits, potential drawbacks, and its transformative impact on individuals, families, and employers. PEOs looking to bring more value-added benefits to their clients have taken notice, and have begun partnering with vendors providing EWA services.

EWA is a financial service that allows employees to access a portion of their net earned, but unpaid, wages before their scheduled payday. Unlike traditional payday loans, which often come with exorbitant interest rates and fees, EWA provides a more affordable and transparent solution. Partnerships between employers and EWA providers make it easily accessible to employees. This arrangement empowers employees to access their hard-earned money when needed most, without resorting to costly borrowing options. Access to an employee’s wages is on a net basis, not gross. EWA is not a loan, or an advance, these are the net funds that the employee has earned up to any given point in the pay period.

The process of utilizing EWA is relatively straightforward. Employees enroll in an EWA program through their employer or a third-party provider, gaining access to their earned wages via a mobile app or web platform. Through this interface, they can track their earned but unpaid wages in real-time. When faced with unexpected expenses or financial emergencies, employees can request a portion of their earned wages through the app. The requested amount is typically transferred to their bank account or prepaid card within minutes or hours, depending on the EWA provider’s policies.

Employers have a responsibility to ensure their employee’s prudent use of EWA. Employers may set controls internally to limit the amount of funds the individual employee has access to at any one time, typically set at 50% of available net wages earned. These guardrails ensure employees always have a minimum amount of money at the end of each pay period.

The benefits of EWA extend to both employees and employers in many ways. EWA provides employees with greater control over their finances, enabling them to access their earnings when needed most. This flexibility empowers individuals to navigate financial challenges with confidence, whether it’s covering unexpected expenses or managing cash flow between pay periods.

By providing an alternative to high-interest payday loans or credit card debt, EWA helps individuals avoid falling into a cycle of financial hardship. Access to earned wages mitigates the need for costly borrowing options, ensuring financial stability and security.

Financial stress can take a toll on individuals’ overall well-being. EWA alleviates financial anxiety and provides peace of mind through access to funds for emergencies which contributes to improved mental health and productivity. Employees can avoid the potentially uncomfortable and sometimes embarrassing process of asking their employer for an advance.

HOW EWA BENEFITS THE EMPLOYER

Employers often experience improved employee retention rates and potential hires view this as a deciding factor. By providing a valuable financial benefit, employers demonstrate their commitment to employee well-being, fostering loyalty and engagement among their workforce.

Some EWA providers offer financial education resources to help employees manage their finances effectively. By equipping individuals with the knowledge and tools to make informed financial decisions, EWA contributes to long-term financial wellness and stability.

While EWA offers numerous benefits, employers should also consider several factors when selecting a provider. It is essential to understand the fees associated with EWA for both employees and employers. Some providers charge fees for accessing wages early, while others offer the service at no cost to the employer. Employers should evaluate fee structures to ensure they align with their budget and the needs of their workforce.

Employers should also identify the preferences and needs of their workforce when selecting an EWA provider. Some providers offer flexibility in how earned wages are accessed, allowing funds to be transferred to any card chosen by the employee. Employers should inquire about the options available to ensure they align with the preferences of their employees.

COMPLIANCE CHALLENGES

EWA isn’t without its challenges and has faced various regulatory compliance issues and undergone a complex history of regulatory scrutiny. For years the PEO industry has attempted to implement EWA into their offerings, however, f regulatory headwinds from state and federal agencies have prevented measurable success.  Only recently did some states, including California, approve EWA access.

EWA services have historically operated in a regulatory gray area due to the absence of specific regulations governing these financial products. As a result, the regulatory environment surrounding EWA has been subject to interpretation and scrutiny by state and federal authorities. Several states have enacted legislation or issued regulatory guidance to address EWA services. These regulations often focus on consumer protection measures, such as fee transparency, disclosure requirements, and caps on

transaction fees. The regulatory landscape varies significantly from state to state, posing compliance challenges for EWA providers operating across multiple jurisdictions, and to PEOs with worksite employees in multiple states.

EWA services may also be subject to federal regulations, particularly if they involve partnerships with financial institutions or banks. Providers that offer EWA through bank partnerships must comply with federal banking regulations, including those related to consumer lending, fair lending practices, and electronic fund transfers.

In response to regulatory concerns, some EWA providers have proactively engaged with regulators to address compliance issues and advocate for clear regulatory frameworks. Industry associations and advocacy groups have also emerged to promote responsible EWA practices and support regulatory efforts that balance consumer protection with innovation.

The regulatory landscape for EWA continues to evolve as policymakers grapple with emerging financial technologies and their implications for consumer financial protection. As EWA services become more widespread and mainstream, regulators are likely to continue monitoring the industry closely and implementing regulations to safeguard consumers while fostering innovation in the financial services sector.

RISK MANAGEMENT

Another growing concern among this new service focuses on fraud within EWA systems which can manifest in various forms. Most challenges are common to all areas of personal and commercial finance and information including identity theft and data breaches which are recognizable to the public, while other instances and tactics are lesser known.

Employees may attempt to manipulate their earnings or work hours to inflate their access to funds through EWA. This can involve falsifying timesheets, exaggerating hours worked, or colluding with coworkers to artificially boost earnings. To mitigate this risk, employers can implement robust time-tracking systems, conduct regular audits of employee hours, and enforce strict policies against time theft and dishonest behavior. EWA providers should have in place robust security measures, such as access controls, encryption, and real-time monitoring, to detect and prevent unauthorized access attempts.

Despite the many challenges, EWA continues to gain approval among regulatory bodies both at the state and federal level; employers are beginning to recognize the talent acquisition and retention benefits. As I have heard many PEO experts say, “you can fight it, but EWA is coming, and it’s not a matter of if, but when”.

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