The PRRA bar exemption, as we call it, is reflective of changed circumstances in the country of alleged persecution. It's really backward-looking to waive that 12-month period that someone would have to wait. If we're looking at November 12, 2020 and onward, then that would already take into account the changed circumstances in the country in terms of the IRB decision.
On November 16th, 2020. See this statement in context.