August 1, 2018

To: Jennifer Jessup, Departmental Paperwork Clearance Officer, US Dept. of Commerce

Re: Docket number USBC-2018-0005

Asian American Advertising Federation (3AF) takes a stance in alliance with the Association of National Advertisers on the possible addition of a citizenship question on the 2020 Census.

The United States Census is a critical source of data and the accuracy of this data plays a crucial role not only in government budgeting but also in diversity of advertising and marketing, especially in the Asian American consumer segment.

Given that 66.4% of Asian Americans are foreign born (2016 American Community Survey), we are concerned that non-citizens may choose not to respond, and, ultimately, not be counted if the citizenship question is added. This may negatively impact many things including reallocation of Congressional seats in districts with high immigrant populations; lower funding for federal programs and limit valuable research in multicultural health and human services. From a marketing perspective, we and other multicultural advertising groups feel strongly that if this citizenship question is added and there is less participation, the Census will have inaccurate data which would result in misallocated marketing resources. According to the Selig Center of Economic Growth, University of Georgia, Asian American consumers wielded $984 billion in buying power in 2017. Undercounting of Asian Americans and misallocated marketing resources represent loss of business opportunities and growth to corporate America.

The Asian American Advertising Federation comprised of advertisers, marketers, media and marketing research firms, corporate marketers, and other industry vendors and partners, strongly opposes the addition of the untested citizenship question to the 2020 Census as it would negatively impact our industry and diversity efforts in the United States in general. The public should not be answering a census that does not meet scientifically sound standards. As professionals who are dependent on the census data and all the data sets that emanate from census data, we stand together against the inclusion of a citizenship question.

About 3AF

The Asian American Advertising Federation (3AF) is a national trade organization comprised of Asian American advertising agencies, Asian market advertisers, Asian media companies and other industry specialists. Its mission is to advance the Asian American marketing and advertising industry for Asian American consumers through education, advocacy, promotion, and increased collaboration of all industry stakeholders including, but not limited to, marketers, agencies, research partners and media. Additionally, 3AF seeks to promote and encourage high standards of conduct and ethics among our members and our industry.

The 3AF Asian Marketing Summit is held annually. More information about the 3AF is available at www.www.3af.org.


Jay Kim, 3AF President

Genny Hom-Franzen, 3AF Executive Director

3AF Board of Directors

Donna Schlueter Bantle, Owner, Asian Media Sales & Consulting LLC

Michael Moon, Chief Operating Officer, Prime Image Media Group LLC