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1 Lauren-Brooke Eisen, Comment on the Inmate Financial Responsibility Program: Procedures, Proposed Rule 1 (2023)

handle is hein.election/cmtoteime0001 and id is 1 raw text is: BRENNAN CENTER Colette S. Peters, Director, Federal Bureau of Prisons Attention: Comments, Amendments to 28 CFR Part 545 320 First Street, NW Washington, DC 20534 March 12, 2023 Re: Comment on the Inmate Financial Responsibility Program: Procedures, Proposed Rule The Brennan Center for Justice at New York University School of Law welcomes the opportunity to submit comments on the Bureau of Prisons' (Bureau) proposed amendment to 28 CFR 545 regarding the Inmate Financial Responsibility Program (IFRP), proposed rule to update, streamline, and clarify IFRP regulations in paragraphs (b), (c), and (d) in section 545.11. The Brennan Center is a nonpartisan public policy and law institute that focuses on improving America's systems of democracy and justice.1 The Brennan Center's Justice Program seeks to ensure a rational, efficient, effective, and fair criminal justice system. As part of that mission, we seek to reduce mass incarceration by reducing the system's racial and economic disparities while also advocating for fundamental reforms that will reduce its size and severity. We commend the Bureau of Prisons for continuing to evaluate and refine its policies that encourage people incarcerated in its prisons to develop financial planning skills. But we strongly oppose the proposed rule to allot 75% of deposits placed in the incarcerated person's commissary account by non-institution (community) sources to the IFRP payment process and the addition of language regarding incarcerated people's ineligibility to earn or apply First Step Act Time Credits as an effect of non-participation in IFRP. However, we are supportive of the Bureau's proposal to delete language requiring quartering in lowest housing status as an effect of nonparticipation in IFRP and deletion of language prohibiting placement in community-based programs as an effect of non-participation in IFRP. Currently, more than 5.4 million adults in the United States are under the supervision of correctional systems.2 The U.S. prison population is largely drawn from the most disadvantaged part of the nation's population, consisting mostly of young men of color, often without a strong 1 This letter does not purport to represent the views, if any, that the New York University School of Law may have. 2 E. Ann Carson and Rich Kluckow, Correctional Pop ulations in the United States, 2021 - Statistical Tables, U.S. DEPT. OF JUSTICE. BUREAU OF JUSTICE STATISTICS, 2023, 4, table 1, Brennan Center for Justice at New York University School of Law 120 Broadway, Suite 1750 New York, NY 10271

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