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

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.

Stop AAPI Hate, a coalition dedicated to ending racism and discrimination against Asian Americans and Pacific Islanders, opposes the proposed revisions to Form AR-11. They argue that the new questions regarding employment, education, and public benefits are unnecessary, create fear of immigration enforcement, and lack sufficient data security protections.

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 Immigrant Law Center of Minnesota, a nonprofit legal services organization, opposes the proposed revisions to the Alien Change of Address information collection. They argue that USCIS lacks the statutory authority to require information on public benefits, employment, and schooling, and that the expansion will deter compliance and discourage eligible individuals from seeking essential benefits.

The commenter, an international educator, opposes the proposed changes to Form AR-11, arguing that the additional questions constitute government overreach and are duplicative. They suggest that the form should remain focused solely on collecting accurate address information, as other tracking mechanisms already exist for various visa holders.

The commenter opposes the proposed rule, arguing that it requests extraneous information and requires legal interpretations that exceed the agency's authority. They contend that the form should be limited to basic identification and mailing address information to avoid invading privacy and wasting government resources.

The Virginia Poverty Law Center (VPLC) opposes the proposed changes to Form AR-11, arguing that the expanded requirements exceed statutory authority and create an unreasonable paperwork burden on noncitizens and state agencies. They contend that the new form acts as a de facto deportability screener that will discourage enrollment in public benefits, ultimately increasing uninsured rates and straining Virginia's healthcare system.

The commenter opposes the proposed expansion of the AR-11 form, arguing that it over-extends the form's purpose into a surveillance tool that collects unnecessary personally identifiable information. They express concerns regarding data security, the lack of a new Privacy Impact Assessment (PIA), and potential violations of privacy policies and the Paperwork Reduction Act.

The commenter opposes the expansion of the AR-11 change of address form, arguing that it violates the Paperwork Reduction Act by creating unnecessary burdens and having low practical utility. They contend that the questions regarding employment and public benefits are irrelevant to an address change and that the information requested may already be available through existing data-sharing agreements.

The commenter, an individual, opposes the proposed changes to the AR-11 form because they believe the added requirements regarding employment and means-tested benefits would be confusing and intimidating for human trafficking survivors and crime victims. They argue that these complexities could cause vulnerable individuals to abandon the care and benefits they are entitled to receive.