Unlawful Presence while STEM OPT is pending

[sdfghhh]

I have a general inquiry on unlawful presence accruals for f-1 students. As per the new policy memorandum, it states that unlawful presence do not accrue while OPT applications are pending. 

 

I do see on the policy memorandum that unlawful presence do not accrue "While the F-1 nonimmigrant’s application for post-completion Optional Practical Training (OPT) remains pending". Does this rule include STEM OPT Extension applications as well? 

 

If it does, will I then still be able to make use of the automatic 180-day extension of OPT while STEM is pending assuming that all of SEVIS, I-20 and I-94 are active ?

 

 

 

 

[newacct]

yes, yes

[sdfghhh]

6 hours ago, newacct said:

yes, yes

If I was 'perceived' to be out of status (e.g. did not report initial OPT employment within 90 days but SEVIS, I-20, and I94 are all active and up-to-date) but applied for STEM OPT Extension, would I still be accruing unlawful presence while the STEM app is pending??