WASHINGTON, D.C. – The Financial Technology Association (FTA) submitted a comment letter in response to the Maryland Office of Financial Regulation’s (OFR) proposed regulations to implement reporting requirements created by HB 1294, an earned wage access (EWA) law passed in 2025.
“We believe House Bill 1294 creates a durable regulatory framework for EWA products and the workers and employers who rely on them,” wrote FTA President and CEO Penny Lee. “It ensures strong, clear consumer disclosure requirements and enshrines into law the consumer protective features of the product. We appreciate OFR’s efforts to establish a reporting framework that promotes transparency and effective oversight.”
FTA urged OFR to ensure that the reporting requirements are appropriately tailored and operationally feasible in order to preserve the benefits of EWA in a manner consistent with the legislative intent of HB 1294. Specifically, FTA urged the rule to:
- Clarify the geographic scope and reporting period for required data; and
- Provide additional specificity for key reporting metrics outlined in Regulations 09.03.10.06(A)(3), (4), (5), (7), and (8).
Read the full comment letter here.
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