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CFPB’s Proposed EWA Rule Sparks Debate

ThomsonReuters

Clark went on to explain that “[w]hile the advisory opinion acknowledged that a proper legal analysis must focus on the substance rather than the form of a transaction, the proposed guidance completely ignores the substance of EWA transactions and their purpose in the larger payroll universe.” 3102 , Code Sec. 3111 , and Code Sec.

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