On August 28, the Connecticut Banking Department issued a consent order against an earned wage access (EWA) provider for allegedly making, offering, and advertising small loans to Connecticut borrowers and receiving payments in connection with those loans without a small loan company license, in violation of Section 36a-556(a) of the Connecticut General Statutes. Connecticut’s Public Act 23-126, effective October 1, 2023 (previously covered by InfoBytes here), defines certain charges in connection with earned wage access advances as “finance charges,” thereby requiring certain EWA providers to obtain a small loan company license. The commissioner had issued a no-action position granting EWA providers additional time to comply, but that position expired on January 1, 2024. The company, which the department noted uses an “employer-integrated” EWA model, applied for a Connecticut small loan license through NMLS in August 2025; the application remains pending at the time of the order. The company represented that it ceased making, offering, advertising, and collecting on small loans in Connecticut as of January 29.

Under the consent order, the company agreed to pay a $200,000 civil penalty and must reimburse all fees collected from Connecticut borrowers since January 1, 2024. The company also agreed to pay $400 in back-licensing fees and to comply with Connecticut’s small loan licensing requirements going forward. The company neither admitted nor denied the allegations, and the commissioner agreed not to take future enforcement action against the company for unlicensed small loan activity occurring before the effective date of the order, provided the company complies with its terms.