The proposed DACA regulation presents serious problems and real opportunities. See the regulation at 86 Fed Reg 53736 (Sept. 28, 2021), https://www.govinfo.gov/content/pkg/FR-2021-09-28/pdf/2021-20898.pdf.
Comments are due on November 29, 2021. Together we can work to improve these rules. We encourage groups to begin considering their own comments. This is our initial take on the issues presented, and we welcome suggestions and comments. ILRC will publish a more detailed discussion and templates for comments on the below topics in the near future.