The Consumer Federation of America (CFA) submitted testimony to the Vermont General Assembly’s House Committee on Commerce and Economic Development, urging lawmakers to reject H.99, a bill that would regulate Earned Wage Access (EWA) services while exempting them from being classified as loans. CFA warns that this exemption would allow EWA providers to sidestep critical consumer protections under the Truth in Lending Act (TILA), leading to high-cost, predatory lending practices that closely resemble payday loans. Research shows that EWA services often trap low-wage workers in cycles of repeat borrowing, with some incurring annual percentage rates (APRs) exceeding 300% due to fees and "voluntary" tips. CFA argues that classifying EWA as credit is essential to ensure transparency, prevent excessive fees, and protect workers from financial instability. The testimony calls on Vermont lawmakers to uphold the state’s strong consumer protections and resist industry-backed efforts to deregulate short-term lending under the guise of financial innovation.