SIIA’s Feedback on Consumer Reporting Rulemaking Panel’s Proposals

In our response, SIIA focuses on the need for a cautious approach when defining data brokers under the Fair Credit Reporting Act (FCRA). We argue that the proposed definition is overly broad and does not align with the FCRA’s original intent. This expansion could encompass entities with beneficial purposes unrelated to consumer reporting, potentially harming the U.S. economy. We stress that defining any consumer information used for a permissible purpose as a consumer report goes beyond what the FCRA allows. We express concern about the potential chilling effect on information dissemination and the associated compliance costs. We also highlight the potential negative impact on the use of credit header data in sectors like healthcare, particularly for underserved populations.