March 10, 2022

Earned Wage Access: Considerations for Policymakers

EarnIn’s mission is to build products for a more equitable financial system and a better life. People have responded with more than 3 million Americans opening the EarnOn App in 2020, and more than 1.3 million using it to Cash Out1, EarnIn’s Earned Wage Access (EWA) product. As of September 2021, EarnIn has performed more than 125 million transactions and provided access to $10 billion in earnings for its members.

The Problem – The Liquidity Gap

With the cost of goods and services rising rapidly, more and more hardworking Americans are living paycheck-to-paycheck and battling a financial system seemingly more focused on engineering new fees than extending the economic ladder people deserve.

This is made worse by a restrictive payment model that favors employers at the expense of employees – forcing them to wait two weeks to get paid for work they have completed. The result is a “liquidity gap:” the dynamic when people have a paycheck coming next week, but have to pay for rent or groceries this week. Over time, this forces people to make impossible choices between meals or medications, co-pays or car payments, groceries or gas, and rent or an essential repair.

This is wrong. In the era of on-demand technology, there is no excuse for this economic injustice that punishes everyday Americans.

The Solution – Earned Wage Access

EarnIn’s Earned Wage Access tool, Cash Out, looks to end this harmful reality by freeing people from the traditional pay cycle – giving them control of their money, starting from when they earn it. Historically, Americans confronting a significant unplanned expense are forced to turn to costly forms of liquidity like payday loans and bank account overdrafts – short-term solutions that carry long-term consequences and escalate, rather than solve, cash flow problems.

Our EWA service bridges the liquidity gap for consumers who are unable to access high-interest bank loans or get approved for credit cards – avoiding financial traps and ensuring they can still achieve financial freedom and pay for essential goods and services when they need them.

How It Works (By Putting the Consumer First!)

EarnIn doesn't charge mandatory fees2, and offers this as a non-recourse, no-interest financial tool. This means credit agencies and debt collectors are never involved, and EarnIn bears the entire risk if a Cash Out isn’t recovered – the consumer bears none. We never share data or sell customer data with third parties. Users may choose to provide voluntary “tips,” though one’s access to Cash Out or any of our financial tools is in no way dependent on tipping.

Our Direct-to-Consumer model means that anyone with a steady paycheck can use our services – regardless of employer. Any employee in the U.S. with a bank account who receives their paycheck via direct deposit can use EarnIn, including small business and government employees.

Earned Wage Access – A Proven Tool

A May 2021 research study of 4,735 EWA consumers showed that EWA helps working families stuck in a traditional pay cycle with the tools they need to manage their finances. It found:

1. 92% of consumers given EWA reported that it helped them to pay bills on time, avoid overdraft fees and payday loans, and become less dependent on credit cards; empowering them to achieve at least one of their financial goals in 2020.

Stat 1

2. A strong majority of EWA users reported a boost in their overall well-being after using the service. Eight in 10 reported feeling less stressed about their financial situation (82%), having higher self-esteem (81%), and an improvement in their mental health (77%).

Stat 2

3. An overwhelming majority of consumers (91%) said they understand how the EWA service works and understand the associated fees.

Stat 3

They also said that without EWA, 44 percent of users would otherwise consider not paying certain bills and more than one-third of consumers would deliberately overdraft their account or use a payday loan because of cash flow constraints.

How Smart Regulations Can Protect Earned Wage Access

This is a tool that must be protected and EarnIn supports regulation for EWA that creates further protections for consumers while recognizing the inherent difference between our product and traditional credit.

We continue to advocate for EWA-specific consumer protection frameworks that ensure fair and equal access to our products. We believe attempts to regulate EWA as credit would jeopardize the entire service, which is fundamentally different from both the predatory credit products that have taken advantage of struggling Americans for years and the exclusive products that make liquidity available to wealthier Americans but remain off-limits to those most in need.

Regulating EWA as credit would impact the accessibility of the product, leading to higher fees and thus further promoting a cycle of debt for lower-income Americans.

More About Us

EarnIn’s comprehensive suite of tools include: Cash Out, which provides access to income as it’s earned; EarnIn Express, FDIC insured, deposit account that gives people the option to receive their paycheck up to two days early; Balance Shield, a low balance alert to help maintain a positive bank balance; Financial Calendar, to help people budget and schedule payments; and Tip Yourself, an easy way to set aside money to reach savings goals. With EarnIn’s EWA product, Cash Out, users can access up to $100 of their accrued earnings per day, and up to $500 of their accrued earnings per pay period.


1Internal data pull from Jan 2021, based on total number of users who cashed out at least once from Jan-Dec 2020

2Fees may apply to use Lightning Speed. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see EarnIn.com/TOS for details

Disclaimer: Graphics contain use of stock images.

EarnIn is a financial technology company, not a bank. Bank products are issued by Evolve Bank & Trust, Member FDIC. The EarnIn Card is issued pursuant to a license from Visa USA Inc.

1Subject to your available earnings, Daily Max and Pay Period Max. EarnIn does not charge interest on Cash Outs.

2Fees apply to use Lightning Speed. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see Earnin.com/TOS for details.

1Restrictions on use of Services and/or third party fees may apply, see earnin.com/privacyandterms for details.

2Balance Shield cash out is subject to your available earnings and daily pay period max. Other restrictions and/or third party fees may apply. For more information visit earnin.com/privacyandterms.

3Tip Yourself Account funds are held with Evolve Bank & Trust, Member FDIC and FDIC insured up to $250,000. Tip Yourself is a 0% APY and $0 monthly fee service. Other restrictions and/or third party fees may apply, see earnin.com/privacyandterms for details.

1Fees may apply to use Lightning Speed. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see  Earnin.com/TOS for details.

2Restrictions and/or third party fees may apply, see Earnin.com/TOS for details.

3Balance Shield cash out is subject to your available earnings and your daily pay period max. Other restrictions and/or third party fees may apply, see Earnin.com/TOS for details.

4Tip Yourself Account funds are held with Evolve Bank & Trust, Member FDIC and are insured by the FDIC up to the standard maximum deposit insurance amount per depositor, per FDIC-insured bank, and per ownership category. Tip Yourself is a 0% Annual Percentage Yield and $0 monthly fee service. Other restrictions and/or third party fees may apply. For more information/details visit earnin.com/tos.

5Up to two days early is based on comparison with traditional banks. Exact timing is dependent on your employer’s payroll policies. For more information on eligibility and requirements of Earnin Express, visit Earnin.com/TOS.

6Your Max on Earnin Express is up to 80% of your payroll or $1000, whichever is less. The 80% is dependent on you routing your full paycheck to Earnin Express. For more information on eligibility and requirements of Earnin Express, visit Earnin.com/TOS.

7Learn how we collect and use your information by visiting our Privacy Policy.

1Disclaimer: Restrictions and/or third party fees may apply, see earnin.com/privacyandterms for more details. Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection.

2Disclaimer: Lightning Speed may not be available to all Community Members. Cash Outs may take up to thirty minutes, actual transfer speeds will depend on your bank connection. Restrictions and/or third party fees may apply, see earnin.com/privacyandterms for details

3Disclaimer: Community Member must have had at least 1 successful debit with EarnIn. Limit to 1 Max Boost per pay period. A boost will not adjust a Community member's daily max. Restrictions may apply, see earnin.com/privacyandterms for more details

*Disclaimer: Balance Shield Cash Out is subject to your available earnings and daily pay period max. Other restrictions and/or third party fees may apply. For more information visit earnin.com/privacyandterms

1Restrictions may apply, see earnin.com/privacyandterms for more details. Tip Yourself Account funds are held with Evolve Bank & Trust, member FDIC and FDIC insured up to $250,000. Tip Yourself is a 0% Annual Percentage Yield and $0 monthly fee service. Your Tip Yourself Account and any Tip Jars are not Savings Accounts. For more information/details visit earnin.com/privacyandterms

2Disclaimer: NO PURCHASE NECESSARY TO ENTER OR WIN. Must be 18 years of age or older and a legal resident of the U.S. or DC. Games begin each Sunday starting 12/6/20 at 9:01 p.m. ET and end the following Monday at 9:00 p.m. ET with the last Game ending 12/19/21. To download the App, view the Official Rules, odds disclosures, prize details, and alternate means of entry, visit https://www.Earnin.com/wewin/game-rules/. Void where prohibited. $10,000,000 grand prize payable over 29 years. Sponsor: Activehours, Inc. (d/b/a Earnin), 200 Portage Ave, Palo Alto, CA 94306.

3Disclaimer: Restrictions Apply. See Earnin.com/wewin/pool-rules/ for more information

1EarnIn does not charge a hidden or mandatory fee for use of its services. Restrictions and/or third party fees may apply. For more info: visit earnin.com/TOS.

*Survey conducted in February 2020 with 889 participants.

* Earnin does not charge hidden fees for use of its services. Restrictions and/or third-party fees may apply. For more info, visit earnin.com/TOS.

1EarnIn is a financial technology company, not a bank. The Deposit Account, Secured Account, and EarnIn Card are issued by Evolve Bank & Trust, Member FDIC. The EarnIn Card is issued pursuant to a license from Visa USA Inc.

2Subject to your available earnings, Daily Max and Pay Period Max. Restrictions and/or third party fees may apply, see EarnIn.com/TOS for details.

3Internal analysis conducted by EarnIn in January 2021, represents total users who Cashed Out at least once from January 1 to December 31, 2020

4This research was conducted online by FTI Consulting’s Digital & Insights team, on behalf of Brigit, MoneyLion & EarnIn. FTI Consulting researched n=4,735 of Brigit, MoneyLion and EarnIn’s Direct to Consumer (D2C) Early Wage Access service consumers between the dates of April 21st, 2021 – May 18th, 2021, and results were weighted in equal proportions to ensure equal representation among the consumers of each participating company. Due to the standard convention of rounding, some totals may not add up to 100%

5Internal survey conducted in February 2020 with 889 participants.

6EarnIn does not charge hidden or mandatory fees for use of its services. Restrictions and/or third party fees may apply. For more info visit earnin.com/TOS

7$4.68 ATM fee = $3.02 ATM + $1.66 bank fee https://www.bankrate.com/banking/checking/checking-account-survey/

8Internal data June 2022- Dec. 2022.

* EarnIn does not charge hidden fees for use of its services. Restrictions and/or third-party fees may apply. For more info, visit earnin.com/TOS.

1Calculated on the VantageScore® 3.0 model. Your VantageScore 3.0 from Experian® indicates your credit risk level and is not used by all lenders, so don't be surprised if your lender uses a score that's different from your VantageScore 3.0. Learn more: https://www.experian.com/assets/consumer-information/product-sheets/vantagescore-3.pdf

2Subject to your available earnings, Daily Max and Pay Period Max. Restrictions and/or third party fees may apply, see EarnIn.com/TOS for details

3Actual response times vary

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