inating in the proposal, has drawn sharply competing views.According to one study by the Federal Reserve Bank of New York, “except for the ten to twelve million people who use them every year, just about everybody hates payday loans.” Supporters of the regulation, such as the National Consumer Law Center, tout the need to protect borrowers from entering into loans they cannot afford to repay, which in turn could lead to a cycle of additional loans and increased fees.By contrast, others have expressed concern that this regulation will drastically limit the availability of small-dollar credit products to consumers who have limited alternatives to borrow money and are often ineligible for more conventional loans with lower rates.Some have taken issue with the concept of requiring an assessment of ability to repay and the proposed cooling-off period (comparing it to requiring a credit card lender to re-underwrite the holder and to force the holder to have to wait two months before using the card again).Opponents have also noted that the proposal adds cost to lenders that have to re-establish a relationship with the borrower two months later, further undermining the availability of credit.[4]Independent observers have had mixed views.The analysis published by the Federal Reserve Bank of New York advocates for more research and focuses on a critical lack of evidence of behavioral “cognitiv