Take action – Write a comment opposing the new attacks on asylum. ALL COMMENTS MUST BE SUBMITTED ON OR BEFORE JULY 15, 2020.

Summary of Proposed New Regulations

There are a dozen sweeping provisions, but here are a few:

  • Completely barring asylum on the basis of gender, which would invalidate protections for individuals seeking safety from gender-based violence 
  • Changing the very definition of “persecution” and “torture” 
  • Allowing judges to deny asylum applications without ever allowing the individual their day in court 
  • Redefining some of the core grounds for asylum claims, including membership in a “particular social group,” which could have a dire impact on LGBTQ individuals 
  • Denying asylum to people who entered the country unlawfully, or who submitted their asylum application more than a year after entering the country without exceptions 
  • Barring an individual who travels to the U.S. through two or more countries from asylum, who has ever failed to file taxes, or who has ever withdrawn a prior application for asylum. 

If this rule goes through, it will also affect the hundreds of thousands of asylum applicants who have already filed their applications and have pending cases. 

For tools and template from Lawyers’ Committee for Civil Rights, click here.

To post a comment, go to the Federal Register and and click the green “Submit A Comment” in the upper right hand corner.


Personalizing your Comment Letter

There is a fairly small character limit if the comment box is used, so we encourage everyone to tweak and play around with the language and formatting of the various templates that are out there, and then save your personalized version to a PDF and upload it as a PDF document. This allows the whole comment to be considered regardless of the character limit. You don’t need an account, but if you want to sign up for one, you’ll be notified when your comment is publicly posted and when it’s mentioned in any future response.  


How to personalize the comment (choose one or more):

  • Change the formatting (remove or change the title/subtitle), switch from bullet points to paragraphs or numbered statements, change the font, change the font size, change the spacing, change the margins, etc.)
  • Delete certain paragraphs that you don’t understand or don’t agree with or don’t think aid anything
  • Add one or more of your own arguments if you think anything wasn’t mentioned
  • Add arguments based in feelings (for example, “I think the proposed regulation is unfair because it is intentionally designed to discriminate against one of the most vulnerable populations in America. People who come to America seeking refuge should not be treated like animals, they should be treated with humanity.” – etc.)
  • Rephrase some or all of the arguments used in the Word doc and put them into your own words (like when you were plagiarizing that paper on Julius Caesar back in 10th grade)
  • Put the arguments into a different order (they’re broken up by bullet point so this should be easy to do)
  • Upload PDF documents you think support your position (in addition to your comment)
  • Delete the formal legal citations if you don’t know what they mean – you’ll want to leave in the ones about 85 Fed. Reg. 36264 (June 15, 2020) though.
  • Sign your name at the bottom
  • Talk about who you are and why your opinion matters
  • Suggest alternatives to the proposed regulation’s new rules (to the extent you can gleam what the new rules are from the attached comment template)

One More Thing!

Please share this information with anyone you can think of that might be interested in submitting a comment to help potential asylees. We need a barrage of comments to slow this process down as much as possible with the hopes that the current administration won’t have enough time left in office to promulgate a final rule.