Justification for additional changes

Request to Amend Form N-400, Application for Naturalization

The reason to request a change to Form N-400, Application for Naturalization, is to comply with Chertoff Initiative Number 23 regarding Social Security numbers. The purpose of the collection of Social Security numbers is to have the ability to verify Social Security numbers and reduce the unauthorized employment of non-citizens. On Form N-400, Social Security numbers are requested from the applicant (See Page 2, Part 3, Question A) and for the applicant’s current spouse (See Page 4, Part 8, Question 4). However, Social Security numbers are not requested for the applicant’s children (See Page 6, Part 9, Question B).

The Chertoff Initiative Number 23 Joint Working Group Study concluded:

a. Collect More SSNs on immigration applications:

USCIS immigration forms may serve as excellent tools for capturing non-citizens’ SSNs. Before implementing the anticipated statutory change, USCIS would need several years to modify its forms and/or take other steps to collect SSNs for all work authorized non-citizens. In addition, USCIS would need to add information in its systems, including the SSN, on work-authorized nonimmigrants who are not currently recorded in any USCIS systems.

…As noted above, the SSN is currently required on only six of 79 USCIS forms and only requested in a data field on 50 of those forms. USCIS should develop forms-related recommendations to increase the collection of SSNs in its systems, particularly from non-citizens who already possess an SSN.

The collection of Social Security numbers for the applicant’s children on Form N-400 would comply with Chertoff Initiative Number 23 because it would capture the Social Security numbers of non-citizens. Furthermore, as cited in paragraph one above, Social Security numbers are already captured for the applicant and applicant’s spouse; and therefore, the collection of Social Security numbers would be consistent throughout the form.