Comment Submitted by The American Immigration Lawyers Association

Summary: The American Immigration Lawyers Association (AILA) opposes the interim final rule as currently drafted, arguing that it creates a consequential post-acceptance denial framework without a general cure process for non-fraudulent errors. They request that USCIS withdraw the interim final rule and replace it with a notice of proposed rulemaking to allow for meaningful stakeholder input and a more practicable framework for electronic signatures.