Should early cash access, with voluntary tips as the cost, be treated as a loan?

An article published by the Associated Press (July 28, 2024) titled “US agency says apps that let workers access paychecks before payday are providing loans”, states that the Consumer Finance Protection Bureau wants the Truth in Lending act to apply to early access to money, and that voluntary tips become a compelled payment due to claims of charity towards the less fortunate. But since the payday is set by the employer, and delayed payment of earned wages is float provided to the employer, is early access a loan or payment due? Should employers be forced to provide this service to avoid overdraft fees by banks? Or should banks be required to coordinate with employers to provide such access to earned wages? 

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