We will focus on how to utilize paycards to minimize both touch points and employee contact when distributing employee related payments. Recently the California Department of Financial Protection and Innovation announced a new opinion on Earned Wages Access (EWA) and this session will discuss how that opinion impacts paycards.
 
Objectives:

• What Vendors are subject to licensing requirements by the California Financing Law (CFL) or California Deferred Deposit Transaction Law (CDDTL)." 
• “A third-party with no financial obligation to the employee could not rely upon this reasoning, because the funds provided would be for the recipient’s temporary use, and the third-party would presumably arrange to recoup the amounts it advanced.”
• DFPI reviewed seven criteria in reaching its conclusion:

      1.    Funding Source – Employer funded
      2.    Data Integration with near zero risk of overpayment – Accurate net earned wage calculation
      3.    Funds Delivery - Instantly to the employee’s account of choice 
      4.    Fee Structure – Transparent and capped
      5.    Typical Usage – Fee to transfer amount and frequency
      6.    No Legal Recourse against employee
      7.    No Other Employee paid products attached to Earned Wage Access