March 28, 2025 — Comments

These are NCLC’s comments supporting a proposed rule by the Consumer Financial Protection Bureau to regulate certain data brokers as “consumer reporting agencies” under the Fair Credit Reporting Act. The proposed rule:

  • provides much needed protections under the FCRA to respond to the growing problem of data brokers, as documented in the administrative record;
  • makes clear that the FCRA’s protections apply to credit header information, i.e. personal identifier information derived from a consumer report, because such information can be highly revealing and its abuse can be harmful to consumers;
  • will promote public safety and national security, while preventing fraud, by automatically covering the sale of credit, debt, and income information under the FCRA;
  • will prevent evasion by data brokers who claim they are merely “conduits,” by codifying established definitions of when an entity “assembles” or “evaluates” information; and
  • provide strong guardrails when businesses obtain the consumer’s written authorization to obtain a credit or other consumer report, by ensuring that the consent is active, knowing, and subject to strong protections.

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