The American Fintech Council (AFC) has addressed concerns about a recent report on Earned Wage Access (EWA) products published by the Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC). In a letter to these organizations, the AFC criticized the report’s methodology and conclusions, arguing that it does not accurately reflect the EWA industry.
Phil Goldfeder, CEO of the American Fintech Council, stated, “Millions of workers use responsible EWA to bridge pay periods and avoid other costly alternatives, including predatory loans and overdraft fees. The CRL report unfortunately recycles the same mischaracterizations we’ve seen before, failing to distinguish between transparent, responsible products and those that pose legitimate concerns. We are proud of our members’ commitment to consumer protection and regulatory compliance and we will continue to advocate for evidence-based policymaking that actually improves financial outcomes for working families.”
According to the AFC, the report relies on a narrow sample of financially strained users to draw conclusions about the broader EWA industry. The council also criticized the report for treating one-time or voluntary fees as annualized APRs, which it described as misleading.
The AFC highlighted that responsible EWA solutions typically include safeguards such as payroll integration, withdrawal limits, and controls to prevent overdrafts and misuse. The organization expressed concern that classifying nonrecourse wage access as credit could limit access to financial tools that benefit workers.
Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC, commented, “This kind of research—built on biased samples, faulty assumptions, and ideological framing—doesn’t move the conversation forward. It risks misleading policymakers and hurting the very communities we all aim to serve. We call on CRL and NCLC to engage constructively with industry leaders and regulators in developing fair, modern rules that recognize responsible innovation can be a force for good.”
The AFC represents fintech companies and banks that provide embedded finance solutions. Its mission is to support responsible innovation in financial services, promote transparency, and encourage policies that improve financial inclusion.