MA: AFC Testimony in Support of H 1119

TO: Massachusetts Joint Committee on Financial Services
FROM: Ashley Urisman, Director-State Government Affairs, American Fintech Council (AFC)
DATE: October 7, 2025
SUBJECT: H 1119

Position: Support

Testimony:

Thank you Chair Murphy, Chair Feeney, Vice Chairs Biele and Moore, and members of the Joint Committee on Financial Services.  My name is Ashley Urisman, and I am the Director of State Government Affairs for the American Fintech Council (AFC), and I am testifying in support of House Bill 1119 (H 1119) this morning.

AFC is the premier trade association representing the leading financial technology companies, including providers of Earned Wage Access (EWA) services. AFC’s mission is to promote a transparent, inclusive, and customer-centric financial system. A core part of our mission is supporting responsible innovation and sound public policy in Finical Services.

EWA is a relatively new financial technology (“fintech”) product that allows workers to access the money they have already earned in a pay period before their scheduled payday. While each provider operates differently, EWA providers leverage technology to reasonably determine the amount of earned but unpaid wages a user will be offered. It is imperative that users maintain access to the type of EWA service that best suits their needs.

Importantly, EWA providers do not charge interest, late fees and impact consumers’ credit scores.

At this time, EWA remains unregulated in Massachusetts. However, H 1119 seeks to change that by requiring EWA providers to register with and submit annual data to the Massachusetts Commissioner of Banks and operate under the supervision of the Commonwealth. This registration requirement creates important consumer protection for your constituents, and accountability for EWA providers.

AFC has established clear standards on what constitutes a responsible EWA product. Our standards require that

• A reasonable no-cost option be made available for all users on all transactions.

• All fees are voluntary, and are disclosed to a user clearly and transparently before the user accepts a transaction.

• Users are never charged interest or late fees.

• EWA transactions are credit invisible: they require no credit checks, and there is no impact to users’ credit score if they cannot repay their EWA transaction;

• EWA transactions are non-recourse and can be canceled at any time; meaning they do not have to be repaid. Failure to repay will not be reported to credit agencies, referred to collections, and users will not be charged any interest or late fees.

AFC believes the guardrails set forth in H 1119 reflect our standards and establish a pragmatic statutory framework for EWA services in Massachusetts.

Thank you for your attention, and I am happy to take any questions you may have.

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