The Software and Information Industry Association (SIIA) strongly opposes the Consumer Financial Protection Bureau’s (CFPB) Proposed Rule amending Regulation V, arguing that it exceeds the Bureau’s authority under the Fair Credit Reporting Act (FCRA) and would have severe unintended consequences. The Proposed Rule broadly defines data brokers and consumer reporting agencies, potentially encompassing businesses that publish and analyze information essential for academic research, fraud prevention, and economic activity. SIIA contends that this overreach would stifle legitimate data-driven practices, hinder fraud prevention efforts, and impose excessive regulatory burdens on industries that have no direct role in consumer credit reporting.
Additionally, SIIA raises concerns that the Proposed Rule’s sweeping scope would restrict free speech, disrupt business operations, and create compliance challenges by holding entities responsible for how downstream recipients use shared information. The rule’s expansive definition of consumer reports could curtail the use of data for research, marketing, law enforcement, and AI model development, ultimately harming consumers and businesses alike. SIIA urges the withdrawal of the rule, advocating instead for policies that balance consumer protection with the benefits of a thriving information economy.