Comment Submitted by Legal Aid Society of Southwest Ohio, LLC, and Legal Aid Society of Cleveland
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Summary: The Legal Aid Society of Southwest Ohio, LLC, and the Legal Aid Society of Cleveland oppose the Interim Final Rule because they argue it violates the Immigration and Nationality Act, undermines due process by rejecting applications without sufficient notice, and removes procedural safeguards for asylum-seekers' employment authorization. They contend that these changes will disproportionately harm vulnerable populations, including survivors of domestic violence and human trafficking, while also causing negative economic consequences for communities.
The Legal Aid Society of Southwest Ohio, LLC, and the Legal Aid Society of Cleveland respectfully submit this Comment to express our strong opposition to the U.S. Department of Homeland Security’s Interim Final Rule (“IFR”), as published in the Federal Register on April 29, 2026. We oppose the IFR for three main reasons. First, the IFR’s fee retention provision violates the Immigration and Nationality Act, longstanding regulatory practice, and Congressional intent. Second, the IFR undermines due process by requiring USCIS to reject pending asylum applications without sufficient notice or an opportunity to be heard. Third, the IFR will require USCIS to immediately terminate asylum-seekers’ employment authorization documents or applications without sufficient procedural safeguards. Please see the attached file for additional comments.