CAE Submits Comment Letter Opposing DHS Proposed Elimination of the International Entrepreneur Parole Program

WASHINGTON, D.C. – John R. Dearie, President of the Center for American Entrepreneurship, today issued the following statement regarding CAE’s submission of a letter of comment regarding the Department of Homeland Security’s announced intention to end the International Entrepreneur parole program:

“Today the Center for American Entrepreneurship submitted a letter of comment in response to the announcement in the Federal Register on May 29, 2018 by the Department of Homeland Security (DHS) of its intention to terminate the International Entrepreneur (IE) parole program.  CAE very much appreciates the opportunity to provide comment.

In our letter, CAE respectfully asserts that DHS’ proposed rule to end the IE parole program is unwise and ill-advised for a number of important reasons:

• The proposed rule does not take adequate account of the vital importance of entrepreneurship to innovation, economic growth, and job creation in the United States and is, therefore, inconsistent with the Administration’s stated policy goal of accelerating economic growth;
• The proposed rule is inconsistent with Executive Order 13767, Border Security and Immigration Enforcement Improvements, issued by President Trump on January 25, 2017, which requires the Secretary of DHS to exercise parole authority when an applicant demonstrates that “significant public benefit” will be derived from such parole;
• The proposed rule overlooks an alarming decline in rates of new business formation in the United States over the past 40 years;
• The proposed rule does not sufficiently recognize the importance of immigrant entrepreneurs to American entrepreneurship and is, therefore, inconsistent with the Administration’s stated policy objective of moving toward an immigration system focused on the economic value of admittees;
• The proposed rule’s enumerated justifications for terminating the IE parole program are wholly insufficient given the critical importance of entrepreneurship to U.S. economic strength and vitality, the alarming decline of entrepreneurship in America, and the importance of immigrant entrepreneurs to revitalizing American entrepreneurship.

As critical context for our comment letter, it is important to emphasize that the United States is one of only a few industrialized nations that does not have a visa category specifically designated for foreign-born entrepreneurs.  In recent years, many other nations – including China, Canada, Germany, France, New Zealand, Australia, and Chile – have overhauled their immigration laws to attract foreign-born entrepreneurs, including American entrepreneurs.  Most recently, on June 13, 2018, the United Kingdom announced the creation of a Startup Visa to attract and retain foreign born entrepreneurs.

CAE acknowledges that the IE parole program is imperfect, and entails certain deficiencies in its approach, structure, requirements, and administration.  Those deficiencies notwithstanding, no law or regulation is a perfect policy solution to the problem it seeks to address, and policymakers should not, as the saying goes, ‘allow the perfect to be the enemy of the good.’

More fundamentally, given the importance of thriving entrepreneurship to the vitality of the U.S. economy, and the historical importance of immigrant entrepreneurs to American entrepreneurship, the Administration, and DHS on its behalf, should do everything possible to attract foreign-born entrepreneurs to launch their businesses in the United States and to create jobs and opportunity for American citizens.”

Read the full letter.

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The Center for American Entrepreneurship (CAE) is a nonpartisan research, policy, and advocacy organization whose mission is to engage and educate policymakers in Washington, and at state and local levels across the nation, regarding the critical importance of entrepreneurs and start-ups to innovation, economic growth, and job creation – and to pursue a comprehensive policy agenda intended to significantly enhance the circumstances for new business formation, survival, and growth.

For more information, visit www.startupsUSA.org

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