Much has been written in recent years about new modes of governance facilitated by discrete policy networks. While emphasis is usually placed on the functional attributes of such governance arrangements, there are occasional observations in the literature about their democratic credentials as well. Such discussions of the democratic potential of governance through networks tend mostly to focus on questions of the efficacy and fairness of these types of interest intermediations. My article seeks to explore the complex prior role that legitimation plays in the policy process associated with governance through networks by way of a case study detailing the recent construction of a new regulatory regime for payday lending in Canada.