CLINIC submitted comments on January 13, 2020 strongly opposing proposed regulations which will impose new limitations on asylum seekers’ ability to obtain an employment authorization document (EAD) while their asylum applications are pending. The proposed rule will force asylum seekers to wait a full year after filing an asylum application before being eligible to seek an EAD; will prevent asylum seekers who missed the one year filing deadline from obtaining an EAD while their application is pending; will prevent asylum seekers who entered without inspection from obtaining an asylum pending EAD; and will require officers adjudicating EADs to make complex eligibility determinations based on possible criminal bars to asylum.