On July 7, Missouri Governor Mike Parson signed SB 103 into law, which prohibits any person from offering earned wage access (EWA) services without registering with the Division of Finance and paying an annual $1,000 fee. The law also requires EWA providers to develop procedures for dealing with consumer questions and complaints, specifies notices required to be given to consumers, and regulates the types of fees that may be charged and the manner in which repayments may be pursued. The law further specifies requirements should the EWA provider solicit, charge, or receive tips or gratuities from consumers. Like Nevada, discussed here, the law specifies that EWA products are not loans or money transmissions under Missouri law. In March 2023, the California Department of Financial Protection and Innovation took the opposite position with respect to EWA products and proposed new regulations under the California Financing Law that would update the definition of loan to include EWA products, except for those offered by employers.
