Agency Information Collection Activities; Reinstatement, With Change, of a Previously Approved Collection for Which Approval Has Expired: Alien Change of Address

The National Immigration Project, a national nonprofit membership organization, opposes the proposed expansion of Form AR-11. They argue that adding questions about employment, education, and public benefits exceeds the form's core purpose of reporting address changes, imposes unnecessary burdens on noncitizens, and creates significant enforcement risks and chilling effects on access to essential services.

End Child Poverty California opposes the proposed changes to Form AR-11, arguing that adding questions about employment and public benefits exceeds the form's original intent and violates the Paperwork Reduction Act. The organization contends that these changes will create a chilling effect, deterring eligible immigrants from seeking public benefits and complying with address reporting requirements due to fear of enforcement.

Legal Services NYC opposes the proposed changes to Form AR-11, arguing that the new requirements for reporting public benefits will create a "chilling effect" that prevents mixed-status families from accessing essential services like housing and nutrition. The organization also contends that the proposal violates the Paperwork Reduction Act, exceeds USCIS's statutory authority, and jeopardizes the confidentiality of crime victims.

Greater Hartford Legal Aid, a non-profit law firm, opposes the proposed changes to Form AR-11 because they add unnecessary and over-inclusive questions regarding employment and means-tested benefits. They argue that this information is already collected elsewhere, creates confusion for recipients of specific services, and could have a chilling effect on parents seeking educational opportunities for their children.

The HANA Center, a community-based organization serving immigrant communities, opposes the proposed changes to Form AR-11. They argue that the expansion of the form to include questions about employment, education, and public benefits exceeds the form's purpose, violates the Paperwork Reduction Act, and creates significant privacy risks and chilling effects for vulnerable populations.

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.

The National Asian Pacific American Women’s Forum (NAPAWF) opposes the proposed revisions to Form AR-11, arguing that the new questions regarding employment, education, and public benefits exceed the form's statutory purpose. They contend that these changes impose unnecessary burdens, create a chilling effect on compliance due to surveillance concerns, and could disproportionately harm AANHPI families by discouraging them from accessing essential services.

UnidosUS, a nonprofit civil rights and advocacy organization, opposes the proposed expansion of Form AR-11 to include questions about public benefits, employment, and school enrollment. They argue the proposal exceeds USCIS's statutory authority, fails Paperwork Reduction Act standards, creates significant privacy and surveillance risks, and will deter individuals from reporting their addresses or accessing necessary public benefits.

Justice for Migrant Women, a national organization advocating for migrant and rural women, opposes the proposed changes to Form AR-11. They argue the expansion of data collection exceeds federal regulations, violates the Paperwork Reduction Act, creates undue burdens on immigrants and government agencies, and poses significant privacy risks for victims of crime and domestic violence.

An immigration attorney and owner of a boutique law firm opposes the proposed changes to the AR-11 form, arguing that the new requirements collect extraneous personal information and impose an unreasonable administrative burden. The commenter contends that the form exceeds its legal authority, lacks practical utility, and should remain in its current, simpler format.