Comment Submitted by Attorneys General of NY, CA, DC, AZ, CO, CT, DE, HI, IL, ME, MD, MA, MI, MN, NV, NJ, NM, OR, RI, VT, VA, WA

Summary: A coalition of state Attorneys General and the District of Columbia opposes the proposed changes to Form AR-11, arguing that the new requirements for employment, education, and public benefits information are overbroad, burdensome, and lack statutory authority. They contend that the agency is attempting to bypass the Administrative Procedure Act and that the collection of such sensitive information at the time of a simple address change is arbitrary and potentially harmful to residents.