Comment Submitted by Demidchik Law Firm, PC

I respectfully request that DHS reconsider implementation of the interim final rule titled “Signatures on Immigration Benefit Requests,” or substantially narrow its application. DHS has a legitimate interest in preventing invalid signatures and protecting the integrity of immigration benefit requests. Applicants and petitioners make factual certifications under penalty of perjury, and their signatures are understandably important. However, the rule is overbroad and unlikely to materially reduce signature fraud, especially as applied to legal representatives and interpreters. A wet-signature requirement does not reliably prevent fraud. A handwritten signature can easily be scanned, copied, inserted into a PDF, reused, or manipulated. Requiring the visual appearance of a handwritten signature may increase paperwork, but it does not reliably authenticate who signed the document. It may instead encourage copied signature images, reused signature pages, and other document manipulation that is difficult to detect. Legal representatives are different from applicants and petitioners. Representatives already provide DHS with verifiable identifying information, including name, address, firm or organization information, licensing or accreditation information, and contact information. Many representatives are also connected to USCIS online accounts or appear repeatedly in USCIS systems. Requiring a wet signature from a legal representative adds little protection. A non-represented person falsely claiming to be represented by an attorney or accredited representative is rare and generally not a useful fraud strategy. Such a claim does not establish eligibility, prove a qualifying relationship, cure inadmissibility, or satisfy the applicant’s burden of proof. If USCIS has concerns about representation, it can reject the Form G-28, contact the representative, request correction, or treat the applicant as unrepresented until representation is confirmed. The rule also appears to underestimate its operational cost. Stricter wet-signature enforcement will likely increase rejected packets, resubmissions, customer-service inquiries, corrections, and disputes over whether a signature is valid. USCIS officers may also need to spend more time reviewing signature issues and distinguishing clerical errors from fraud. The private burden is also significant. Immigration filings often involve strict deadlines, expiring status, age-out issues, employment authorization, removal proceedings, and family-unity concerns. A technical signature issue can create consequences far beyond the paperwork defect itself, especially where the signature belongs not to the applicant or petitioner, but to a representative or interpreter whose identity can be verified through less burdensome means. For these reasons, I respectfully request that DHS withdraw or postpone implementation of the rule pending further review. The current digital G-28 process is unnecessarily confusing. It requires multiple clicks, page changes, unclear prompts, and a workflow that leaves many applicants and petitioners unsure what they are confirming, even when they are competent computer users. A system that requires extensive outside guidance or training to use properly is not a sufficient substitute for a simple, user-centered filing process. The better solution is not more wet signatures. The better solution is better authentication: secure electronic attestations, representative-account verification, clearer G-28 workflows, direct confirmation prompts, audit trails, and targeted fraud review when there is an actual reason to suspect misconduct. In sum, the rule is overbroad as applied to legal representatives and interpreters, insufficiently connected to actual fraud prevention, and likely to increase burdens without materially improving the integrity of immigration filings. DHS should reconsider implementation. At minimum, it should not require legal representatives and interpreters to provide wet signatures where their identities and certifications can be verified through more reliable and less burdensome electronic means. Ellie Chang Demidchik Law Firm, PC