Comment Submitted by California Rural Legal Assistance, Inc.

Summary: California Rural Legal Assistance, Inc. (CRLA), a nonprofit law firm, opposes the proposed changes to Form AR-11, arguing that the expansion to collect employment, schooling, and benefits information is unnecessary and exceeds statutory authority. They contend that the new requirements will create confusion, deter compliance, and discourage noncitizens from accessing essential services due to privacy concerns and fear of immigration consequences.