Comment Submitted by Anonymous
AnonymousOpposeOther
Summary: The commenter argues that the proposed expansion of Form AR-11 into a broad benefits-reporting mechanism lacks sufficient statutory authority. They contend that current laws only require address reporting and targeted investigations, rather than mandatory recurring disclosures from millions of filers.
INA §265 (8 U.S.C. §1305) is an address-reporting statute, not a general benefits disclosure statute. INA §287 (8 U.S.C. §1357) authorizes targeted investigations, not recurring mandatory disclosures from approximately 2.68 million annual filers. Expanding Form AR-11 into a broad benefits-reporting mechanism raises major questions concerns and requires clear congressional authorization. USCIS should identify the specific statutory authority permitting this expansion or withdraw the proposal.