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

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.

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.

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.

A coalition of 19 organizations advocating for immigrant survivors of domestic violence, human trafficking, and other abuses opposes the proposed changes to Form AR-11. They argue that the expansion of the form to collect employment, education, and benefits information exceeds the form's original purpose, creates safety risks for survivors, and violates the Paperwork Reduction Act.

The Community Legal Aid Society, Inc. (CLASI), a non-profit law firm, opposes the proposed changes to Form AR-11. They argue that the expansion of the form violates the Paperwork Reduction Act by imposing undue burdens on individuals and service providers, fails to account for statutory exemptions, and raises significant privacy concerns regarding the collection of unnecessary personal data.

Church World Service, a faith-based humanitarian organization, opposes the proposed changes to Form AR-11 because they expand the form's scope beyond simple address reporting to include sensitive information on employment, education, and public benefits. The organization argues that these changes violate the Paperwork Reduction Act, create a chilling effect on compliance due to privacy and surveillance concerns, and could prevent eligible families from accessing vital services.

The League of United Latin American Citizens (LULAC) opposes the proposed revisions to Form AR-11, arguing that the expansion to collect information on employment, education, and public benefits is unnecessary and violates the Paperwork Reduction Act. They contend that these additional questions create a "chilling effect" that may discourage eligible families from seeking public benefits and do not address the underlying issues of interagency communication and notice delivery.