On September 7, the Council, along with the American Immigration Lawyers Association, submitted a comment responding to DHS's Interim Final Rule on the agency's plan to implement electronic service of bond-related notifications to people who pay bonds, known as obligors, to secure the release of individuals in immigration detention. The rule would allow certain notifications about the bond process to be sent to obligors electronically. To complete the electronic delivery, DHS plans to rely on CeBONDS, a new system adopted by the agency that permits obligors to complete some of the steps of the bond payment process online.

The comment highlights some of the issues users have encountered using CeBONDS such as;

1. The lack of language access for those who don't speak English;
2. The agency's failure to provide an option for obligors who don't have access to a computer, internet, or a banking institution, all of which are required to use CeBONDS;
3. and the lack of information about the new systems.

The comment asserts these issues will impact CeBONDS' new function, allowing obligors to receive notices electronically.

While the Council and AILA welcome the use of technology to upgrade aspects of the bond payment process, the agency needs to provide clear information about CeBONDS uses and its privacy risks.