Comment Submitted by Juan Huezo

RIN # 1615-AD17 U.S. Citizenship and Immigration Services DHS Docket No. USCIS-2026-0166 I am a graduate student who is working on their master’s in international Affairs with an emphasis on Immigration, and I respectfully request the language on the rule be adjusted for clarity and its excessiveness/stringent of application of the terms be amended. Under its current language, applicants are left without recourse if any errors are found. If DHS is implementing this procedure to catch false signatures but already has a prior system to find said false signatures. What is the point of formalizing this language now? Additionally, if signatures can be denied post acceptance isn’t this an additional obstacle/cost to simply deny applicants? Also, the language itself is unclear in its rationale and evidence for the purpose of codifying this to deter applicants. The overall lack of clarity found in Part II Executive Summary when referencing procedure and why it’s being implemented. It states, “believes this codification will, in turn, better encourage compliance with signature requirements, reduce the number of rejections caused by invalid signatures, protect the integrity of the benefit request adjudication, and allow USCIS to recoup the costs associated with enforcing these requirements” (Executive Summary, USCIS-2026-0166). How will this codification help with compliance? Why is codification needed, if its already implemented and in use. What is the problem that is exactly being addressed? If, this policy is already being implemented what’s the additional purpose of codifying it? I am concerned that we may be missing an aspect of this challenge. One of the questions that should be asked, is who bears the cost? From my understanding this falls on the public. Additionally, what exactly is the purpose and how will this discourage invalid signatures. The problem of purpose and deterrence can be found in section D. Purpose and Scope of this Rule it states “DHS believes that this increase may be because denials are not currently codified and rejection of the request under the existing regulations, 8 CFR 103.2(a)(7)(ii)(A) (2025), is not sufficient to discourage parties from exploiting USCIS limitations on signature validation at intake” (IV. Discussion, Part D, USCIS-2026-0166). How will codifying this change the situation and how specifically will it deter requestors? What is the rationale exact? What exactly will be changed in this situation that does not already exist? What support is provided to crease a connection between the idea that this may be because of denials not being codified. More importantly how will implementing this sufficiently discourage parties from exploring USCIS limitations on signature validations. The punitory action of losing one’s place in line if they simply forget to include a document. In the section titled Signatures, section 1. Filing Requirements, it states “With respect to the submission of that benefit request, 8 CFR 103.2(a)(7)(ii)(A) states that USCIS will reject the request if not “[s]igned with a valid signature.” Further, “a benefit request which is rejected will not retain a filing date.” 8 CFR 103.2(a)(7)(ii). In addition, 8 CFR 103.2(a)(7)(iii) states that “a rejection of a filing with USCIS may not be appealed.” This implies that requester will lose their place in line with a minor issue? In terms of real-world applicability, does this mean that if a person misses one document and/or has a minor issue in their paperwork loses their place in line. In a system where backlogs are normal and the wait time can take years; this would be severely unfair and punitory in action. Is there any scenario where an applicant can keep their place in line? I am unsure if the agency is missing this point or is it by design. Either way, an applicant is left without any recourse. I respectfully request that DHS address the following issues: The overall lack of clarity when referencing procedure and why it’s being implemented, what exactly is the purpose of this proposed change and how will this discourage invalid signatures and lastly, the punitory action of losing one’s place in line if they simply forget to include a document.