Comment Submitted by MALDEF (Mexican American Legal Defense and Educational Fund)

Summary: MALDEF, a Latino civil rights organization, urges DHS to rescind the proposed fee increase for Form I-246 applications. They argue that DHS lacks the statutory authority under 8 U.S.C. § 1356(m) to impose the fee and that the proposal is arbitrary and capricious because it relies on stale data and fails to provide a rational connection between fee waivers and the financial burden on applicants.