Comment Submitted by Anonymous

Comment on U.S. Citizenship and Immigration Services Docket No. USCIS-2026-0166 — Signatures on Immigration Benefit Requests This comment addresses the Interim Final Rule (IFR) governing signature validity and the shift to complete denial for signature deficiencies under 8 CFR 103.2(a)(7). While supporting filing integrity, the catch-all phrase extending to "other document[s] that require[s] a signature" introduces severe operational, environmental, and economic friction. 1. Distinguishing Requestor Authorization from Third-Party Certification The preamble states a valid signature represents the "requestor's authorization... and accountability for the contents of the request". While vital for forms, a translator executing a certification under 8 CFR 103.2(b)(3) does not authorize the immigration case; they merely attest to a document's accuracy. Applying case-wide denial and fee forfeiture to any "other document" forces practitioners to demand paper wet-ink signatures out of fear. Applying case-level denial consequences to a third-party document is entirely disproportionate to ensuring applicant authorization. 2. Refuting the "No Cost" Baseline & Domestic Talent Constraints Section V.E estimates that codifying this authority results in no additional costs. This assessment overlooks logistical disruptions. Banishing secure digital workflows forces manual "print-wet-sign-scan-merge" cycles, slowing processing and inflating consumer costs. Furthermore, relying exclusively on U.S.-based linguists is structurally impossible for hundreds of rare or indigenous dialects due to an absolute domestic talent deficit. Global talent constraints mean rigid paper requirements create logistical barriers and artificial processing delays. 3. Quality Control, Aesthetics, and Environmental Contradictions Forcing paper interventions decreases document security, degrades quality, and causes needless waste. Merging high-resolution text with a manually printed, signed, and scanned page compromises the professional aesthetic of the translation. Furthermore, if a practitioner insists that a multi-page translation be printed and scanned as a single file to avoid "stitching" detection, agencies are forced to waste massive amounts of paper. This directly contradicts the federal objective to eliminate paper filings under the Government Paperwork Elimination Act (GPEA). Additionally, the rule permits a flattened scan of a handwritten mark, which carries no verifiable tracking data and can be easily altered. Conversely, it restricts secure e-signature platforms that generate cryptographic, tamper-evident audit trails (capturing IPs and timestamps), providing adjudicators with vastly superior fraud-detection capabilities. 4. A Modern Solution: Remote Online Notarization (RON) A secure solution lies in embracing modern digital infrastructure, specifically Remote Online Notarization (RON) and secure e-signatures. State-authorized RON platforms provide multi-layer identity verification and a tamper-evident digital seal backed by an unalterable audit trail, eliminating copy-and-paste risks and manual page-assembly errors while preserving business efficiency. Recommended Revisions I respectfully request that USCIS clarify the final rule to: - Re-evaluate Case-Level Penalties: Reconsider application denial and fee retention for technical defects, ensuring third-party supporting documents are insulated from case-level consequences. - Provide an Opportunity to Cure: Mandate that if a signature on an ancillary document is questioned, USCIS will issue an RFE to allow verification or replacement. - Permit Secure Digital Infrastructure: Explicitly allow translators and third-party certifiers to utilize secure e-signatures and Remote Online Notarization (RON) supported by an unalterable digital audit trail. - Publish Distinct Guidance for Supporting Evidence: Clarify that form restrictions do not apply to secondary evidence. Supporting documents are overwhelmingly issued with secure digital signatures, including financial records (bank statements), academic credentials (certified electronic transcripts/diplomas), employment letters, tax documentation (IRS transcripts/W-2s), and foreign civil registries (birth/marriage certificates). Expecting a paper standard for these externally generated documents is entirely impractical. Conclusion A balanced immigration system should mitigate fraud without creating unnecessary procedural hurdles. By distinguishing core form authorizations from third-party certifications, avoiding paper-dependent policies that contradict federal mandates, and explicitly permitting secure digital solutions like Remote Online Notarization and electronic evidence, USCIS can achieve its objectives. This approach ensures robust file integrity, protects applicants from case delays, and allows American small businesses to maintain secure, efficient, and technologically advanced operations.