CLINIC Comments in Opposition to Proposed Changes to Forms EOIR-31 and EOIR-31A
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CLINIC submitted comments in response and opposition to the Justice Department's Information Collection published on July 13, 2020, revising Form EOIR-31, Request for New Recognition, Renewal of Recognition, Extension of Recognition of a Non-Profit Religious, Charitable, Social Service, or Similar Organization, and Form EOIR-31A, Request by Organization for Accreditation or Renewal of Accreditation of Non-Attorney Representative. CLINIC urged the withdrawal of these proposed revised forms because they attempt to create policy change through the form revision process and the amount of information required in the revised forms is burdensome, goes far beyond the requirements in the regulations, and will make the recognition and accreditation process significantly more difficult for eligible organizations.