ILRC Comment Opposing Interim Final Rule regarding Signatures for Immigration Benefit Requests

The Immigrant Legal Resource Center (ILRC) submitted comments opposing USCIS's interim final rule on signatures for immigration benefit requests. The policy unfairly penalizes immigrants for minor, correctable signature errors. The comment explains that denying applications after they have already been accepted can result in the loss of filing fees, lengthy delays, and even permanent loss of immigration benefits when eligibility depends on the original filing date. ILRC also argues that the rule is arbitrary and capricious under the Administrative Procedure Act because USCIS failed to adequately justify its departure from longstanding practice of allowing applicants to correct signature deficiencies. Finally, ILRC contends that allowing USCIS to retain filing fees after denying applications for technical signature errors exceeds its statutory cost-recovery authority. ILRC urges DHS to withdraw the rule.