Practice Alert: DHS Reduces Refugee NOIT Response Deadline to 10 Days
Today, DHS published an interim final rule (IFR) reducing the response period for refugees who receive a Notice of Intent to Terminate (NOIT) from 30 days to 10 days, effective immediately. Invoking exceptions to the Administrative Procedure Act, DHS bypassed prior notice and comment, while advocacy groups warn the shortened deadline may leave refugees with little meaningful opportunity to respond. Practitioners representing refugees who have not adjusted status should monitor developments and act promptly upon receipt of a NOIT.