#paynews Hello, everyone.

#paynews EWA is becoming more common especially in the current labor market.

#paynews Make sure your employees are earning a living wage, establish regular employee schedules and try to avoid changing them, and consider offering employees budgeting assistance.

#paynews Analyze how your employees are receiving their pay – direct deposit, payroll card, or paper check – because EWA operates electronically.

#paynews Start with asking how the model works.

#paynews What are the employer’s responsibilities?

#paynews Ask whether the vendor is in compliance and knows the gray areas of regulation.

#paynews Some employers are limiting the number of times an employee can withdraw early pay,

#paynews I heard that some employers are phasing in the program.

#paynews Are you part of a decision-making team with your employer?

#paynews You should consider whether the model will require payroll reconciliation.

#paynews So far, the IRS seems satisfied that taxes are paid on the usual schedule but this could change and we don't know about daily depositors under the $100,000 rule.

#paynews At APA, we are beginning to get questions from state legislators.

#paynews Laws on child support don't prevent a state from collection from an EWA payment but this would be administratively difficult for employers and state agencies.

#paynews Employers need to make sure that funds are available on the regular pay day for garnishments. EWA should be disposable earnings only.

#paynews The difficulty is viewing EWA under the existing legal structure. This is not a pay day loan but a different technology.

#paynews The states that are engaged are focused on consumer protections.

#paynews We prepared a report to help payroll professionals. It's available on APA's website.

#paynews Through the APA Government Relations Task Force, we have responded to New Jersey, South Carolina, Utah, and Nevada.

#paynews We appreciate everyone joining us today.