I'm confused by what's happening.
We have notice AO-1534 establishing a Minority farmer register using form AD-2035
We have notice CM-695, implementing departmental regulations using form AD-2106.
Reading between the lines, although quickly so I'm possibly missing something, the register is intended to collect data from and through "outreach organizations", the data stays on paper, and goes to the Department. The AD-2106 is just passed out to program applicants, presumably SCIMS is updated. A question: can SCIMS reflect whether the race, ethnicity, sex category is based on customer input or is the old eyeball test?
Seems to me it would have been much better to have issued one notice covering the subject.
Looking at the USDA strategic plan it appears USDA believes its current data on customers is good enough for analysis (despite GAO's problems with it).
My own feelings on the subject I stated in these comments on the Federal Register notice the Department put out.
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