Comment in Response to Proposed Rule on Payday, Vehicle-Title, and Certain High-Cost Installment Loans

We appreciate the opportunity to respond to the Bureau of Consumer Financial Protection’s (Bureau) proposed rule governing 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 how best to regulate certain credit products.

On July 22, 2016, the Bureau published to the Federal Register a proposed rulemaking with request for comment regarding the regulation of “Payday, Vehicle Title, and Certain High-Cost Installment Loans.” The Mercatus Center at George Mason University submitted a comment in response to that notice. The suggestions made in that comment are still relevant and could help the Bureau as it assesses how best to regulate an important and frequently misunderstood credit market. For this reason, we are resubmitting the previous comment, which is attached.

If we can be of any further assistance, please do not hesitate to ask.

Attachment

“Comment on the CFPB’s Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans” (Public Interest Comment)