Administrative and Public Comments
The Lawyers’ Committee for Civil Rights Under Law regularly provides legal and policy analysis through rulemaking and public comment procedures to administrative agencies and other government entities. Our public comments and submissions highlight how policy proposals that touch on issues across our project areas would impact Black communities and other communities of color.
These submissions reflect our commitment to ensuring that laws and regulations preserve civil rights, protect against discrimination, and advance equal opportunity.
Below you can explore our recent public comments and policy submissions.
December 2025
Joint Comment on the Equal Credit Opportunity Act
December 15, 2025 – CFPB has issued a proposed rule that would gut fair housing longstanding protections that prohibit discrimination in lending. The Equal Credit Opportunity Act (“ECOA”) has protected women and people of color from credit discrimination for 50 years. However, the proposed rule changes to ECOA Regulation B would remove disparate impact from ECOA: making it easier for creditors to discriminate against marginalized communities. The proposed rule would also narrow the legal use of “special purpose credit programs”: programs financial programs specifically designed to benefit groups that have been historically marginalized.
Lawyers’ Committee and ACLU joined in a comment voicing their strong opposition the proposed rule and requesting that CFPB withdraw the Notice of Proposed Rulemaking
October 2025
Comment Opposing Petition to Require Proof of Citizenship for Federal Voter Registration
October 20, 2025 – The Lawyers’ Committee for Civil Rights Under Law submitted comments urging the U.S. Election Assistance Commission (EAC) to reject a petition by America First Legal Foundation seeking to require documentary proof of citizenship (DPOC) on the National Mail Voter Registration Form. The Lawyers’ Committee argued that such a requirement is unnecessary, unlawful, and inconsistent with decades of congressional, judicial, and EAC precedent rejecting similar efforts. The comment underscores that non-citizen voting is statistically negligible, while DPOC mandates would disenfranchise millions of eligible voters—especially Black, Latino, Indigenous, low-income, disabled, and elderly citizens who face barriers to obtaining qualifying documents. The organization called on the EAC to reaffirm its long-standing interpretation of the National Voter Registration Act and uphold accessible, nondiscriminatory voter registration for all eligible citizens.
Joint Comment Opposing Proposed Changes to Higher Education Data Collection (IPEDS ACTS Survey)
October 14, 2025 – The Lawyers’ Committee for Civil Rights Under Law and the American Civil Liberties Union Foundation submitted joint comments urging the U.S. Department of Education to withdraw its proposed Admissions and Consumer Transparency Supplement (ACTS) to the Integrated Postsecondary Education Data System (IPEDS). We warned that the proposal rests on flawed and biased assumptions about higher education admissions and could perpetuate racial discrimination rather than prevent it. The comment explains that the proposed data collection—focused narrowly on GPAs and test scores—misinterprets the Supreme Court’s Students for Fair Admissions decision, risks violating student privacy laws, and fails to provide reliable, validated, or legally compliant data. The Lawyers’ Committee and ACLU called on the Department to withdraw the proposal and instead develop a transparent, legally sound process that supports genuine educational equity and civil rights enforcement.
September 2025
Joint Comment on Proposed Rulemaking for Public Service Loan Forgiveness (PSLF) Program
September 17, 2025 – Responding to the Department of Education’s destructive efforts to undermine the Public Service Loan Forgiveness (PSLF) program, the Lawyers’ Committee for Civil Rights Under Law joined 63 organizations in submitting a joint comment, co-led with the National Women’s Law Center (NWLC) and the NAACP Legal Defense Fund (LDF).
The coalition emphasized that the Department lacks authority to rewrite the statutory terms of PSLF and warned that the proposed rule risks viewpoint discrimination in violation of the First Amendment. The comment further underscored that the Department’s attempt to expand its power would impose billions in additional debt burdens and disproportionately harm marginalized groups—including Black, Brown, Indigenous, LGBTQ+, immigrant, low-income communities, and people with disabilities.
LCCRUL’s Comment on Proposed Rulemaking for Public Service Loan Forgiveness (PSLF) Program
September 17, 2025 – Separately, the Lawyers’ Committee for Civil Rights Under Law submitted its own detailed comment opposing the Department of Education’s proposed rule. The Lawyers’ Committee argued that the rule would give the Department unchecked authority to define what constitutes a “substantial illegal purpose,” allowing it to revoke PSLF eligibility from employers—and by extension, their employees—without due process.
The comment highlighted that such changes would disproportionately impact Black workers and other communities of color, deepening inequities in access to public service careers and economic mobility. The Lawyers’ Committee urged the Department to withdraw the proposed rule and preserve PSLF as a critical pathway toward debt relief and equal opportunity
June 2025
Joint Comment Opposing DOE’s Rescission of Title IX Gender Equity Protections
June 16, 2025 – The Lawyers’ Committee for Civil Rights Under Law joined The Leadership Conference on Civil and Human Rights and 57 national organizations in opposing the Department of Energy’s direct final rule rescinding Title IX regulations that support gender equity in education. The coalition warned that removing these protections would undermine decades of progress for women and girls, particularly women of color, in fields where they remain underrepresented—such as STEM and technical training. The comment emphasized that the Department’s use of an expedited “direct final rule” process is inappropriate for such a consequential change and urged DOE to withdraw the rule and uphold Title IX’s promise of equal opportunity in education.
Comment Opposing DOE’s Direct Final Rule on Title VI Nondiscrimination Protections
June 15, 2025 – The Lawyers’ Committee for Civil Rights Under Law submitted a significant adverse comment opposing the Department of Energy’s Direct Final Rule rescinding key Title VI nondiscrimination regulations. The proposed rule would eliminate long-standing protections against policies with unjustified discriminatory effects and weaken language access requirements for individuals with limited English proficiency. The Lawyers’ Committee warned that these changes would undermine civil rights enforcement, deepen racial inequities, and violate the Administrative Procedure Act by bypassing the public notice-and-comment process. We urged DOE to immediately withdraw the rule and maintain robust Title VI protections for communities of color and other marginalized groups.
May 2025
Comment to FTC on Technology Platform Censorship and Content Moderation
May 21, 2025 – Responding to the Federal Trade Commission’s request for comment, the Lawyers’ Committee emphasized that online platforms must retain the ability to moderate harmful content to protect the civil rights of Black people and other communities of color. The comment outlines the dangers of online hate, harassment, and disinformation—including threats to voter participation—that disproportionately target marginalized groups. The Lawyers’ Committee cautioned the FTC against regulations that would discourage content moderation and urged the FTC to adopt measures that require greater transparency, fairness, and accountability from platform operators.
April 2025
Submission to House Privacy Working Group on Federal Data Privacy and Civil Rights
April 7, 2025 – The Lawyers’ Committee for Civil Rights Under Law urged the House Energy & Commerce Privacy Working Group to include strong civil rights protections in any federal data privacy framework. The comment highlights how weak or absent privacy standards disproportionately harm communities of color through discriminatory algorithms, exploitative data practices, and online redlining. The Lawyers’ Committee called for clear prohibitions on discriminatory data use, mandatory bias testing for automated decision-making systems, data minimization, consumer rights to access and delete data, regulation of data brokers, and strong enforcement mechanisms at both federal and state levels.