Posts Tagged ‘Comment’

ASISTA opposes harmful proposed DOJ rules

By Admin • January 4, 2021
On December 28, 2020, ASISTA submitted two comments in response to two proposed Department of Justice, Executive Office of Immigration Review (EOIR rules) which would limit access to relief for immigrants with matters in Immigration Court, including survivors.

ASISTA Comment on USCIS’ Harmful Proposed Rule on Fees

By Admin • January 6, 2020
On December 30, 2019, ASISTA submitted its organizational comment in response to USCIS’ new proposed rule which increases immigration fees, further limits the criteria and availability of fee waivers, and includes a transfer of millions of dollars from USCIS to ICE. You can read ASISTA’s comprehensive comment here .

ASISTA and NOW Submit Opposition to USCIS Tip Form

By Admin • April 18, 2019
On April 16, 2019, ASISTA and the National Organization for Women (NOW) submitted a comment in opposition to the proposed USCIS Tip Form, as the form would be a tool for abusers and perpetrators of crime to weaponize the immigration system against survivors, with impunity. Read our comment here .

Comment Today! USCIS Fraud Tip Form

By Admin • March 29, 2019
On February 15, 2019 the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) published a proposed form for notice and comment to collect information from the general public regarding purported immigration fraud. At ASISTA, we are particularly concerned about this Fraud Tip form as it represents another tool for abusers and perpetrators of crime to weaponize the immigration system against survivors, without consequence or repercussion. This is extremely problematic and dangerous, as abusers often use the threat of deportation as a tool to maintain power and control over survivors. We urge you and your organization to submit comments detailing your opposition to this proposed form. The comment period closes Tuesday, April 16th. ASISTA, ILRC and the Arab American Institute have developed a comprehensive fact sheet on the new USCIS Tip Form. In addition, you can use this template comment to speak out against this harmful form. We are grateful to ILRC, AAI, ACLU, AAPCHO, NIJC, CLINIC, and End Domestic Abuse WI for their contribution to these resources. Using the template as a starting point, we suggest agencies individualize their comments with their own reasons and experiences why the proposed rule would harm immigrant survivors and their families so that they may be counted as a unique submission . In addition, to the extent possible, your comment submission should be in your own words and based upon your agency’s concerns and interests. The goal is to maximize the number of unique comments to have the greatest impact. Deadline for submission is April 16, 2019. Comments can be submitted online at: https://www.regulations.gov/document?D=USCIS-2019-0001-0001 Please remember to review and clear any formatting before submission. Resources: USCIS Fraud Tip Fact Sheet Template Comment in Opposition to USCIS Tip Form

ASISTA opposes DHS Proposed Rule on Public Charge

By Admin • December 11, 2018
On December 10, 2018, ASISTA filed a Comment on DHS’ Proposed Rule on Public Charge . DHS’ proposed rule will harm immigrant survivors of domestic and sexual violence as well as survivors of human trafficking. Access and use of public benefit programs may make the difference in whether survivors and their children can escape abuse. ASISTA opposes the proposed rule because DHS should not put survivors in the position of choosing between their immigration status and their ability to survive after abuse.

Recent Posts

ASISTA Practice Alert: USCIS Extreme Vetting Policies and Their Implication for Immigrant Survivors (Dec. 12, 2025)

By Maria Lazzarino • December 12, 2025
This Practice Alert summarizes USCIS’s new extreme vetting policies, including broad adjudication holds, re-review of previously approved cases, and heightened discretionary scrutiny, and explains their serious implications for immigrant survivors seeking safety and stability. It also provides practical guidance for practitioners on preparing clients for the impact of these measures and on developing case strategies and potential legal challenges.

ASISTA Practice Alert: Impact of HR-1 on Trafficking Survivors (Oct. 1, 2025)

By Maria Lazzarino • December 12, 2025
On July 4, 2025, President Trump signed HR-1, the “One Big Beautiful Bill Act” (OBBBA), which significantly impacts immigrant survivors of human trafficking. The law imposes new filing fees for immigration benefits, motions, and appeals before USCIS and EOIR, establishes additional financial penalties for certain immigration violations, and eliminates eligibility for a range of federal public benefits for many immigrants who were previously considered “qualified,” including trafficking survivors. This Practice Alert reviews these fee and penalty changes, explains the new restrictions on public benefits, and outlines the impact on trafficking survivors seeking T visas and other forms of humanitarian relief, offering guidance for practitioners on how to mitigate the law’s potential harms.

Amicus Briefs on Birthright Citizenship Executive Order (Spring 2025)

By Maria Lazzarino • June 11, 2025
In May and June 2025, ASISTA joined partners at Boston College School of Law, Harbor COV, and Tahirih to submit an amicus briefs to the First and Fourth Circuit Courts of Appeals in cases challenging the executive order on birthright citizenship. ASISTA and partners highlighted the importance of maintaining a preliminary injunction against implementing the order. If the order were implemented, many immigrant mothers of U.S.-born children would only be able to prove their child’s citizenship by submitting documentation about the child’s father’s immigration status. For survivors of intimate partner violence, just knowing the need for this documentation could make it difficult or impossible to leave the abusive relationship. For survivors of sexual assault or trafficking, contacting the perpetrator for the paperwork could put them and their families in immediate physical danger. Using real-life examples, the brief illustrates the stakes if immigrant parents were forced to choose between maintaining their safety and establishing their children’s rights. It urges the court not let this become reality. Read the First Circuit Brief, Doe v. Trump , here ; read the Fourth Circuit Brief, Casa, Inc., et al. v. Trump , here .

Alien Enemies Act Alert (May 29, 2025)

By Maria Lazzarino • May 30, 2025
On March 14, 2025, President Trump attempted to invoke the Alien Enemies Act of 1798 to justify carrying out deportations without the due process of immigration proceedings. Since then, multiple federal courts have ruled the invocation was unlawful, but the government continues to fight for its usage, including before the U.S. Supreme Court. On May 16, 2025, the Supreme Court maintained a temporary prohibition on the deportations planned in Texas and sent the issue back to the lower courts. ASISTA celebrates the positive rulings but notes with condemnation that the push against them is ongoing. Check ASISTA’s alert: The Fight to Protect Survivors from the Alien Enemies Act Continue.

ASISTA Practice Alert: USCIS Wet Ink Signature RFEs & NOIDs (April 24, 2025)

By Maria Lazzarino • April 28, 2025
Practitioners have reported receiving RFEs and NOIDs in cases submitted with electronically reproduced signatures for original, wet ink signatures where USCIS has requested the original, wet ink signatures. This Practice Alert describes what USCIS’ current signature policy is and what options practitioners have in these cases.