Read a PDF of our statement here.

On Thursday, the Legal Defense Fund (LDF) submitted comments to the Office of Management and Budget (OMB) regarding the agency’s proposal to update its standards for maintaining, collecting, and presenting federal data on race and ethnicity. OMB requested comments on its suggested changes, which include removing people of Middle East and North African (MENA) descent from the definition of “white” and adding MENA as an ethnicity; using a combined question rather than two separate questions to ask about race and ethnicity; disaggregating race and ethnicity data; and updating outdated and offensive terminology used in required reporting categories to collect federal race and ethnicity data.

In its comments, LDF highlights the importance of improving federal data collection in ways that accurately reflect and account for the increasing diversity of America’s population. In particular, LDF lauds the agency’s proposal to add MENA as an ethnicity – answering longtime calls from people of MENA descent to have their distinct experiences and cultural backgrounds recognized in this way. However, LDF urges the agency to conduct further testing to ensure that its proposal to ask about both race and ethnicity in one question does not result in the undercounting of people who identify with both a race and an ethnicity, such as Afro-Latinx populations.

“How we collect, present, and interpret federal data collection regarding race and ethnicity is key to determining if particular policies and systems are impeding or helping advance access and opportunities for all people,” said LDF President & Director, Janai S. Nelson. “Currently, people of MENA descent are categorized as white, yet may experience a lived reality quite different from that identity. It is imperative that our federal programs accurately account for our nation’s increasing diversity, and the impact of race and ethnicity on the lived experiences of people in America. More research is also needed to ensure that our country’s Latinx residents are able and encouraged to accurately claim their intersectional identity.”


Founded in 1940, the Legal Defense Fund (LDF) is the nation’s first civil rights law organization. LDF’s Thurgood Marshall Institute is a multi-disciplinary and collaborative hub within LDF that launches targeted campaigns and undertakes innovative research to shape the civil rights narrative. In media attributions, please refer to us as the Legal Defense Fund or LDF. Please note that LDF has been completely separate from the National Association for the Advancement of Colored People (NAACP) since 1957—although LDF was originally founded by the NAACP and shares its commitment to equal rights.