Comment Submitted by New Jersey Consortium for Immigrant Children

Summary: The New Jersey Consortium for Immigrant Children (NJCIC) opposes the proposed changes to Form AR-11, arguing that the collection of information regarding employers, schools, and public benefits exceeds USCIS's statutory authority and violates the Paperwork Reduction Act. They express concern that the new requirements will impose an undue burden on immigrant children, create a chilling effect on their access to rights and benefits, and pose safety risks for those seeking victim-based protections.