Signatures on Immigration Benefit Requests

Parker Mackenzie Coyne, a law student at American University, opposes the proposed rule, arguing that it evades the Administrative Procedure Act (APA) and constitutes arbitrary and capricious conduct. The commenter highlights inconsistencies in the Department's logic regarding administrative burden and suggests that technological alternatives for signature verification exist.

The Berkeley Society of Friends opposes the interim final rule regarding signatures on immigration benefit requests, arguing that it creates a framework for post-acceptance denials without a general cure process. They request that USCIS withdraw the rule and instead publish a notice of proposed rulemaking to allow for meaningful public comment and the consideration of electronic signature methods.

A graduate student studying international affairs opposes the proposed rule, arguing that it lacks clarity and creates punitive consequences for applicants. The commenter expresses concern that minor errors could lead to applicants losing their place in line without recourse, and questions the necessity of codifying procedures that are already in practice.

Paulina Mendez opposes the proposed rule because it allows USCIS to deny benefit requests with invalid signatures without providing a mechanism for applicants to correct honest mistakes. She argues the rule creates a revenue-generating penalty that disproportionately harms vulnerable populations, such as non-English speakers and those without legal representation, and suggests using Request for Evidence (RFE) processes instead.

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.

An immigrant applicant expresses support for the proposed action, emphasizing the need for clear, transparent, and efficient procedures. They argue that improved accessibility and clearer instructions help applicants comply with the law and navigate the immigration system more fairly.