How can I renew my combo card while the EB-5 regional center program is on hold?

USCIS has said it would reject I-485, I-765, and I-131. Without the authorization behind the I-485, the others would follow.

Yes, the combo card renewal process as part of a pending I-485 petition will run in parallel with your pending I-526 petition, even during the lapse of the EB-5 Regional Center program. USCIS has not provided definitive confirmation as to whether they will adjudicate I-765/I-131 renewals based on a pending I-485 (filed based on an approved I-526 RC petition). There are reports of individuals receiving combo card renewals during the Regional Center program lapse. Moreover, individuals with a pending I-485 can file a combo card renewal application in advance of the EAD/AP expiration date and receive an automatic 180-day extension of work authorization. The extension begins on the date the EAD expires and continues for up to 180 days, unless USCIS denies the renewal application. I would strongly recommend filing the EAD/AP renewal application ahead of time (4-6 months prior to the current expiration date) to take advantage of this provision.

Wait until re-authorization.

The adjudication of combo card extension has been inconsistent. However, you should still file the extension as soon as possible.

Apply now. USCIS is now processing collateral benefits for EB-5 adjustments with pending but does not plan to issue a public statement. Just file.

Despite the "official" line from USCIS, we have heard from multiple sources that ancillary benefits such as EADs/APs are still being adjudicated. Will they update their official policy on this despite the fact that they are still reviewing and approving these benefits? Unlikely. Fun times.