We appreciate the opportunity to respond to the proposed rulemaking by the Bureau of Consumer Financial Protection (CFPB or Bureau) on payday, vehicle title, and certain high-cost installment loans. The Mercatus Center at George Mason University is dedicated to bridging the gap between academic ideas and real-world problems and to advancing knowledge about the effects of regulation on society. This comment, therefore, does not represent the views of any particular affected party or special interest group but is designed to assist the Bureau as it considers whether—and, if so, how—to proceed with rulemaking regarding small-dollar lending. More generally, this comment seeks to assist the Bureau in embracing a regulatory approach that serves consumers by fostering competitive, innovative, accessible, and diverse credit markets.

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