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STATUS: Concluded

Lea la información en español.

Make your voice heard about a new
proposed rule that would close the door on the vast majority of asylum seekers in the United States.  The rule threatens the safety of survivors of all types of human rights abuses, including gender-based violence such as rape, forced marriage, honor crimes, female genital mutilation/cutting, domestic violence, human trafficking, and punishment because of one’s sexual orientation/gender identity.

Learn more about asylum and gender-based violence.

Before the proposed rule can be finalized, the government is required to review and respond to each unique public comment submitted by organizations or individuals responding to the rule. This is your chance to make your voice heard.*

Below is a sample comment for the general public. For other sample comments for domestic violence/sexual assault agencies and advocates, legal service providers working with immigrant survivors, and others, please see this list of additional resources.  

It is critical that you DO NOT simply copy and paste the model comment into the form you submit. The government will only review and respond to unique comments. When expressing your opposition to the proposed rule, please be sure to reformulate the text, adding your own voice and speaking to your own professional expertise and personal experiences, or those of people you know.  Explain why, in your view, the U.S. must preserve access to protection for all asylum seekers, including those fleeing gender-based violence.  For additional suggested key points to include in your comment, please see below.



All public comments are due by July 15, 2020 at 11:59 ET.


Comment Template:

I am writing in response to the United States Department of Homeland Security (DHS) United States Citizenship and Immigration Services (USCIS) and Department of Justice (DOJ) Executive Office for Immigration Review (EOIR) (the Departments) Joint Notice of Proposed Rulemaking (NPRM): Procedures for Asylum and Withholding of Removal; Credible Fear and Reasonable Fear Review; RIN 1615-AC42 / 1125-AA94 / EOIR Docket No. 18-0002/ A.G. Order No. 4714-2020 published in the Federal Register on June 15, 2020. I firmly oppose the proposed rule for the following reasons:

[Insert your own points as to why you oppose the rule.  Also, if applicable, explain the nature of your relevant professional or personal expertise and how it informs your opinion.]



“The proposed rule will unfairly prevent most asylum seekers from having their day in court.  Each case should instead be carefully considered because the stakes are so high if protection is denied.  Survivors of gender-based violence are particularly at risk in their home countries.  The societies they flee often accept violence against women and gender-non-conforming individuals as normal.  They are forced to navigate not only the impact and trauma of the violence itself, but also society’s and perhaps one’s own family’s judgement of them for daring to protest. In many countries law enforcement officers ignore or dismiss reports of gender-based violence, unwilling to intervene to protect survivors from what they see as a ‘private matter.’ Their hesitation to protect survivors, and often, complicity in harming them, shows that gender-based violence can in fact be a systemic, state-sanctioned human rights abuse.  Full access to asylum must be preserved for all, including survivors.  Prohibiting most asylum claims from going forward and being approved goes against long-established U.S. immigration law and ignores our international obligations as a signatory to the United Nations Refugee Convention.  The Departments should promptly withdraw the proposed rule, and instead promote policies to protect and support asylum seekers.”


Additional Key Points:

  • Our laws have long honored the right to seek asylum and those who do so should not be criminalized and denied a fair process. Asylum is not a ‘legal loophole’ being ‘exploited’ by the masses. There is no evidence that most are trying to ‘game the system.’ This rule is unnecessary because there are already effective policies and practices our government uses to detect fraud.  When there are a lot of claims, for example, from women fleeing domestic violence, it is because such violence is unfortunately very prevalent, not because the claims are false.   There have been reports describing how survivors who were deported were killed by their abusers upon returning home.
  • Asylum was created as a path to safety for people harmed because of something about them they cannot – or should not have to – change. Gender or sexual orientation/gender identity, like race, religion, nationality, or political opinion, are fundamental aspects of one’s personhood as recognized broadly in international human rights law.  All survivors of persecution in any form deserve a chance to seek protection.
  • If survivors of gender-based violence are harmed by non-government agents (eg, family members), and the police refuse to help them, they are in need of international protection in the form of asylum.



*Any interested person is allowed to submit a comment on the rule. Comments submitted through the below link are sent directly to the Department of Justice and Department of Homeland Security. Your full name is required, and submitting other personally identifying information, like your address, is optional. You can choose to keep your name and other information from being posted online by including the words “PERSONALLY IDENTIFIABLE INFORMATION” and including the specific information you want to keep from being posted online. Similarly, if you include information about your business, you can write “CONFIDENTIAL BUSINESS INFORMATION” and the specific identifying information you want to be not available to the public. Otherwise, all information included in your comment will be available to the public.

Although anyone who is interested may submit a comment, please be aware that the comments go to the Department of Homeland Security, which includes USCIS, and the Department of Justice, which includes the immigration courts and Board of Immigration Appeals. Tahirih cannot guarantee whether a non-citizen’s immigration case could be affected by submitting a comment. We recommend that you consult with an attorney about the potential risks of submitting a comment.

Comments must be in English or have a certified English translation of any portion that is written in a language other than English.

After you have submitted your comment, please let Tahirih know that you commented.

Confirmation of comment submission

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Do Something!

Make your voice heard about a new proposed rule that would close the door on the vast majority of asylum seekers in the United States.