This week, the National Consumer Reporting Association filed a comment to the CFPB in connection with a proposed rule, euphemistically called the “Protecting Americans From Harmful Data Broker Practices.” While billed as a data broker regulation, it would impose sweeping changes to the U.S. consumer reporting system in ways that harm consumers, businesses, nonprofits, and government agencies.

Our comment makes four points. First, the proposed rule should be withdrawn. Second, the Proposal’s definition of “assembly and evaluating” defies logic and law, and harms small businesses. Third, banning meaningful access to personal identifying information, sometimes called “credit headers,’’ grants permissible purposes to fraudsters. Fourth, regulating data brokers is both beyond the scope of law and dangerous for consumers.