Today, the CFPB issued a report on the growth of “earned wage” cash advances , by which employers partner with third party companies to offer employees loans based on earned wages. The report found that, in addition to fees, these loans typically have an APR of 109.5%. Along with the report, the CFPB issued a proposed interpretive rule, setting out the agency’s view that these products are subject to the Truth in Lending Act. The CFPB’s press release, with links to the report and proposed rule, is available here.