On May 8, 2020, ILRC submitted a comment to USCIS opposing a recent USCIS Information Collection notice published in the Federal Register on April 10, 2020 to overhaul the form I-864 Affidavit of Support. USCIS used a form change process under the Paperwork Reduction Act to propose extensive changes in the I-864, I-864 A and I-864 EZ which would further discourage sponsors from pledging support for family-based immigrants.

The form changes contradicted existing regulations by changing requirements for counting household size, requesting unreliable credit reports from private agencies, requiring detailed bank account information from sponsors, and requiring notarization of sponsor’s signatures, in contravention to existing federal laws.