USDA has published a notice of proposed rulemaking on nondiscrimination. There's several changes, among them expanding the basis for political beliefs and gender identity. I won't comment on that, but I will on requiring agencies to collect race, ethnicity and gender data on their customers, albeit on a voluntary basis.
I'm not sure how that works. John Jones comes in and applies for a farm loan. He refuses to give his REG data. He is turned down. He appeals on the basis of REG. Can the agency say we didn't know you were REG, so our basis for turning you down was totally rational and legal? Can Jones say: look at me, it's obvious that I'm REG and you approved a loan in a very similar case to Sandra Smith, who wasn't REG? And the agency says, but Sandra didn't provide REG data, so we approved her on a totally rational and legal basis? Can the agency say only if you provide REG data can you appeal any rejection on the basis of REG?
My bottomline: I don't see how this approach to the REG data helps in the decision making and appeals process.
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