Strike 1: African Americans disproportionately (54%) have lower, poor, or no credit score. Probably don't need to say anymore about that because we all know America is "not there yet" on racial equality. RBL is a step backward in time on that problem.
Strike 2: One in five Americans (@ 20%) are penalized with higher loan rates or out right loan denials because they have no credit history. Young Americans, such as recent high school and college graduates just starting out in life, are the most harmed. These young people are considered by risk-based lenders to be "guilty (and penalized) until proven innocent", not exactly in line with our American approach to justice - which is, last time I checked, "innocent until proven guilty".
Strike 3: A recent national, independent survey found that over one-third (34%) of Americans' credit reports contained erroneous data. And, even more outrageous, the burden (time and costs) of correcting the errors falls on the American consumer - you and me.