I-601A Supporting Statement.I-601A Expansion FR 5.12.16

I-601A Supporting Statement.I-601A Expansion FR 5.12.16.doc

Application for Provisional Unlawful Presence Waiver

OMB: 1615-0123

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 1615-0123 can be found here:

Document [doc]

Download: doc | pdf

SUPPORTING STATEMENT FOR

APPLICATION FOR PROVISIONAL UNLAWFUL PRESENCE WAIVER OF INADMISSIBILITY

OMB Control No.: 1615-0123

COLLECTION INSTRUMENT(S): FORM I-601A

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Section 212(a)(9)(B)(i)(I) and (II) of the Immigration and Nationality Act (INA or the Act) provides for the inadmissibility of certain aliens who have accrued unlawful presence in the United States. There is also a waiver provision incorporated into section 212(a)(9)(B)(v) of the Act, which allows the Secretary of Homeland Security to exercise discretion to waive the unlawful presence grounds of inadmissibility on a case by case basis.

On March 3, 2013, USCIS implemented the provisional unlawful presence waiver process codified at 8 CFR 212.7(e), which allows certain immediate relatives of U.S. citizens to obtain a provisional waiver of the unlawful presence ground of inadmissibility prior to departing the United States to attend the immigrant visa interview abroad. See Provisional Unlawful Presence Waivers of Inadmissibility for Certain Immediate Relatives, Final Rule, January 3, 2013, 78 FR 536. The information collected from an applicant on an Application for Provisional Unlawful Presence Waiver of Inadmissibility, Form I-601A, is necessary for U.S. Citizenship and Immigration Services (USCIS) to determine not only whether the applicant meets the requirements to participate in the streamlined waiver process provided by regulation, but also whether the applicant is eligible to receive the provisional unlawful presence waiver.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Form I-601A is used by certain immediate relatives of U.S. citizens to request a provisional waiver of the unlawful presence grounds of inadmissibility under section 212(a)(9)(B)(v) of the Act and 8 CFR 212.7(e). An applicant can request this waiver prior to departing the United States to appear at a U.S. Embassy or consulate for an immigrant visa interview. USCIS will use the data collected on this form to determine whether the applicant is eligible for a provisional waiver of the unlawful presence grounds of inadmissibility under section 212(a)(9)(B)(v) of the Act. The form serves the purpose of standardizing the application; having the form also ensures that applicants provide the necessary information required for USCIS to assess their eligibility to participate in the new, streamlined waiver process and their eligibility for the waiver itself.

USCIS is submitting this revision request because DHS is proposing to expand the provisional unlawful presence waiver program to include all statutorily eligible relatives of U.S. citizens and LPRs regardless of the type of immigrant category upon which they seek to immigrate. DHS is also proposing to allow an applicant to show that his or her LPR spouses or parents, in addition to U.S. citizen spouses or parents, may suffer extreme hardship if an applicant were denied admission to the United States. Currently, the INA allows a showing of extreme hardship either to the applicant’s U.S. citizen spouse or parent or to the LPR spouse or parent. See INA 212(a)(9)(B)(v).

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The use of Form I-601A provides the most efficient means currently available for collecting and processing the data required to determine whether the applicant qualifies for a provisional waiver of the unlawful presence grounds of inadmissibility under section 212(a)(9)(B)(v) of the Act. This form will reside on the USCIS Web site (www.uscis.gov) but the public will not be able to immediately submit it electronically. The public, however, will be able to complete and save the form electronically, but it must be mailed to USCIS.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

A review of USCIS Forms Inventory revealed no duplication of effort, and there is no other similar information currently available which can be used for this purpose.

Filings: According to DHS’ proposal, applicants can apply for a provisional unlawful presence waiver based on an approved immigrant visa petition (Form I-130, Form I-140, or I-360) or based on selection by the Department of State (DOS) to participate in the Diversity Visa (DV) Program. The rule would apply to the categories of aliens who may be eligible to obtain a provisional unlawful presence waiver. Applicants in removal proceedings continue to qualify if their cases have been administratively closed and not recalendared before the filing of the Form I-601A. Applicants who withdraw a pending Form I-601A before final adjudication or for whom USCIS denies the request for a provisional unlawful presence waiver can file a new Form I-601A based on the same immediate relative petition. However, applicants can only file a new Form I-601A after withdrawal or denial, if their immigrant visa cases are still pending with DOS and they have notified DOS of their intent to file a new Form I-601A.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

This collection of information does not have an impact on small businesses or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The collection instrument submitted under this request is submitted on an “as needed” basis in connection with an immigration benefit request. The information provided must be current, thus previously submitted data cannot be used. If the information is not collected, USCIS will not be able to fulfill its core mission of providing immigration benefit and information services while ensuring the integrity of the immigration system. USCIS would not be able to properly assess the alien's eligibility for the requested provisional waiver of the unlawful presence grounds of inadmissibility under section 212(a)(9)(B) of the Act and, as a result, the applicant’s request will not be accurately adjudicated.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• Requiring respondents to report information to the agency more often than quarterly;

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any document;

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On July 22, 2015, USCIS published a proposed rule, RIN 1615-AC03, Expansion of Provisional Unlawful Presence Waiver, in the Federal Register. With that rule, USCIS requested comments regarding this information collection and invites the public to submit comments during a 60 day comment period. USCIS received four public submissions with multiple comments in response to the proposed rule. USCIS has addressed all public comments received in connection with that proposed rule and the imbedded 60-day information collection notice in the final rule. USCIS has also created an appendix to this supporting statement with a summary of the comments received and its responses to these comments. The appendix is available as part of the information collection request submitted to OIRA under this control number in RegInfo.gov and in the rule’s eDocket No. USCIS-2012-0003 at www.regulations.gov.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

USCIS does not provide payments or gifts to respondents in exchange for an immigration benefit sought by the respondent.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation or agency policy.

There is no assurance of confidentiality. The system of record notice associated with this information collection is United States Citizenship and Immigration Services Benefits Information System, which was published in the Federal Register on September 29, 2008 at 73 FR 56596. The privacy impact assessment associated with this information collection is USCIS Benefits Processing of Applicants other than Petitions for Naturalization, Refugee Status, and Asylum dated September 5, 2008.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This information collection contains questions that are of a sensitive nature. Respondents must provide information regarding previous immigration and criminal history. The sensitive questions are necessary because applicants are not eligible for a provisional unlawful presence waiver if USCIS has reason to believe that they are inadmissible for any ground provided in section 212(a) of the Act other than unlawful presence under section 212(a)(9)(B)(i) of the Act. USCIS will review affirmative answers for these questions and the applicants’ description of the events that led to the creation of an immigration or criminal history record to section 212 of the Act to determine if the applicant may be inadmissible for a ground other than unlawful presence under section 212(a)(9)(B)(i) of the Act. USCIS obtains the consent of the applicant to this required information on page 5 of Form I-601A, which USCIS instructs the applicant to read prior to signing the Form I-601A on the same page.

Below is a list of those specific sensitive questions and their needs:

26. Are you currently in removal, exclusion, or deportation proceedings? This includes being subject to a final order of removal, exclusion, or deportation or a Department of Homeland Security (DHS) removal order that reinstates a prior removal, exclusion, or deportation order.

Note: If your case has been administratively closed, you are still “in removal proceedings” until the Department of Justice’s Executive Office for Immigration Review (EOIR) terminates or dismisses your case. However, you are eligible to apply for a provisional unlawful presence waiver if EOIR has not placed your removal proceedings back on EOIR’s calendar in order to continue your removal proceedings.

If you answered “Yes” to Item Number 26., select the statement below that most accurately describes your current situation.

JUSTIFICATION: This question is needed to determine whether the individual qualifies for the provisional unlawful presence waiver. An individual who is in removal proceeding is generally not eligible to seek a provisional unlawful presence waiver unless he or she can demonstrate that his or her removal proceedings have been administratively closed and not re-calendared by EOIR prior to filing of the Form I-601A.

27.a. I am in removal, exclusion, or deportation proceedings that are administratively closed and, at the time of filing my Form I-601A, have not been placed back on EOIR’s calendar to continue my removal, exclusion, or deportation proceedings.

Note: Provide a copy of the administrative closure order. Also, if U.S. Citizenship and Immigration Services (USCIS) approves your provisional unlawful presence waiver, you should seek termination or dismissal of your removal, exclusion, or deportation proceedings before you depart the United States for your immigrant visa interview.

27.b. I am subject to a final order of removal, exclusion, or deportation.

27.c. I am subject to a DHS order that reinstates a prior removal, exclusion, or deportation order seeking my removal, exclusion, or deportation from the United States.

27.d. I am currently in removal, exclusion, or deportation proceedings that are not administratively closed or in removal, exclusion, or deportation proceedings that were administratively closed, but EOIR has placed my proceedings back on its calendar in order to continue them.

27.e. I am subject to a judicial order of removal issued by a Federal court.

JUSTIFICATION for 27.a. – 27.e.: These related questions are needed to determine whether the individual qualifies for the provisional unlawful presence waiver. An individual who is in removal proceeding is generally not eligible to seek a provisional unlawful presence waiver unless he or she can demonstrate that his or her removal proceedings have been administratively closed and not recalendared by EOIR prior to filing of the Form I-601A.

Answer Item Number 28. – 34. If you answer “Yes” to any question in Item Numbers 28. – 34., you may be ineligible for a provisional unlawful presence waiver if USCIS has reason to believe that you may be subject to grounds of inadmissibility, other than unlawful presence under INA section 212(a)(9)(B)(i)(I) or (II) at the time of your immigrant visa interview with a Department of State (DOS) consular officer. For each “Yes” response for Item Number 28. – 34., provide the location and date of the event and a brief description in Part 9. Additional Information. For Item Number 30., if you were not charged with any crime or offense, provide a statement or other documentation from the arresting authority or prosecutor’s office to show that you were not charged with any crime or offense. If you answer “Yes” to Item Number 31., you must provide all related court dispositions.

28. Have you EVER knowingly and willfully given false or misleading information to a U.S. Government official while applying for an immigration benefit or to gain entry or admission into the United States?

JUSTIFICATION: This question is required because an affirmative answer may render applicant ineligible for a provisional unlawful presence waiver and result in denial of the Form I-601A under 8 CFR 212.7(e)(4)(i) for an inadmissibility other than unlawful presence. Without this question, we would not be able to properly identify all applicants who fall into this category of aliens who are ineligible for a provisional unlawful presence waiver.

29. Have you EVER knowingly assisted or attempted to assist the entry of someone, even a family member, into the United States without the benefit of a valid travel document in violation of U.S. law?

JUSTIFICATION: This question is required because an affirmative answer may render an applicant ineligible for a provisional unlawful presence waiver and result in denial of the Form I-601A under 8 CFR 212.7(e)(4)(i) for an inadmissibility other than unlawful presence. Without this question, we would not be able to properly identify all applicants who fall into this category of aliens who are ineligible for a provisional unlawful presence waiver.

30. Have you EVER been arrested, cited, or detained by a law enforcement officer (including immigration and military officers) in the United States, your home country, and/or any other country for any reason other than traffic violation?

31. Have you EVER been charged, indicted, convicted, imprisoned or jailed in the United States, your home country, and/or any other country for any crime or offense?

32. Have you EVER trafficked in or are you NOW trafficking in any controlled substance?

33. Are you NOW or have you EVER knowingly assisted, abetted, conspired, or colluded with others in the unlawful trafficking of any controlled substance?

34. Are you NOW or have you EVER been engaged in prostitution?

Answer Item Number 35.a. – 41. If you answer “Yes” to any question in Item Numbers 35.a. – 41., you may be ineligible for a provisional unlawful presence waiver if USCIS has reason to believe that you may be subject to grounds of inadmissibility other than unlawful presence under INA section 212(a)(9)(B)(i)(I) or (II) at the time of your immigrant visa interview with a DOS consular officer. For each “Yes” response for Item Numbers 35.a. – 41., provide a complete explanation in Part 9. Additional Information.

Have you EVER ordered, incited, called for, committed, assisted, helped with, or otherwise participated in any of the following:

35.a. Acts involving torture, genocide, or human trafficking?

35.b. Killing any person?

35.c. Intentionally and severely injuring any person?

35.d. Engaging in any kind of sexual contact or relations with any person who was being forced to participate or through use of threat?

35.e. Limiting or denying any person’s ability to exercise religious beliefs?

JUSTIFICATION: These questions are required because an affirmative answer may render applicant ineligible for a provisional unlawful presence waiver and result in denial of the Form I-601A under 8 CFR 212.7(e)(4)(i) for an inadmissibility other than unlawful presence. Without this question, we would not be able to properly identify all applicants who fall into this category of aliens who are ineligible for a provisional unlawful presence waiver.

Have you EVER:

36.a. Served in, been a member of, assisted in, or participated in any military unit, paramilitary unit, police unit, self-defense unit, vigilante unit, rebel group, guerilla group, militia, or insurgent organization?

36.b. Served in any prison, jail, prison camp, detention facility, labor camp, or any other situation that involves detaining persons?

37. Have you EVER been a member of, assisted in, or participated in any group, unit, or organization of any kind that used or threatened to use any type of weapon against any person?

38. Have you EVER assisted or participated in selling, providing, or transporting weapons to any person who to your knowledge, used them against another person?

39. Have you EVER received any type of military, paramilitary, or weapons training?

40. Have you EVER recruited, enlisted, conscripted, or used any person under 15 years of age to serve in or help an armed force or group?

41. Have you EVER used any person under 15 years of age to take part in hostilities or to help or provide services to people in combat?

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate*	Total Annual Respondent Cost
Individuals or Households	Application for Provisional Waiver of Inadmissibility, Form I-601A.	52,918	1	1.5 hours	79,377	$10.59	$840,602.43
Individuals or Households	Biometrics	52,918	1	1.17 hours	61,914.06	$10.59	$655,669.90
Total**		52,918			141,291.06		$1,496,272.33

* The above Average Hourly Wage Rate is derived from the current Federal minimum wage rate of $7.25 per hour inflated by 1.46 to account for the full cost of employee benefits (such as paid leave, insurance, and retirement), which results in a time value of $10.59 per hour. Sources: Federal minimum wage information gathered from the U.S. Department of Labor, Wage and Hour Division, available at http://www.dol.gov/dol/topic/wages/minimumwage.htm (last accessed Mar. 5, 2015). Employer benefits adjustment information gathered from the U.S. Department of Labor, Bureau of Labor Statistics. “Economic News Release, Table 1. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, September 2014.” Dec. 10, 2015, available at http://www.bls.gov/news.release/ecec.htm.

** Estimates may not sum to total due to rounding.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995; (2) to achieve regulatory compliance with requirements not associated with the information collection; (3) for reasons other than to provide information or keep records for the government; or, (4) as part of customary and usual business or private practices.

There is no cost burden to respondents for responding to this information collection or for start-up, maintenance, and operating costs associated with completing the paperwork. For informational purposes, there is a $585 application fee and an $85 biometric services fee associated with this information collection.

This information collection may impose some out-of-pocket costs on respondents in addition to the time burden for the form’s preparation

1. Translations. Respondents might incur burden for translations of documents in foreign languages. USCIS continues to evaluate the estimated costs associated with these services. USCIS continues to seek comments on the possible cost associated with this step of the process.

2. Preparers. Many respondents may hire third parties to complete this type of request so there may be a cost for a preparer to assist in the form completion process. USCIS estimates that approximately 26,483 Form I-601A respondents hire attorneys who assist with these requests. The cost associated with these services is estimated at $2,499,863 (26,483 respondents x 1.5 hours per response x $62.93 (BLS National Mean Hourly Wage rate)).

3. Records. Many respondents may be required to provide, among other things, expert opinions, records attesting to employment or business ties, such as payroll records or tax statements; evidence of monthly expenditures such as mortgages, rental agreements, bills and invoices; financial and medical records; membership records; volunteering confirmations; evidence of cultural affiliations; birth, marriage, adoption certificates, etc., to establish extreme hardship.

USCIS, however, estimates that respondents will incur an estimated cost of $3.75 average postage cost for each respondent to submit the completed package to USCIS. The total estimated postage cost associated with this collection is $198,442.5.

The total estimated public cost associated with this type of request is $2,698,305.5.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annualized Cost Analysis:

a. Printing Cost $ 2,804

b. Collecting and Processing $ 35,452,256

c. Total Cost to the Government $ 35, 455,060

Government Cost

USCIS establishes its fees using an activity-based costing model to assign costs to an adjudication based on its relative adjudication burden and use of USCIS resources. Fees are established at an amount that is necessary to recover these assigned costs, plus an amount to recover unassigned overhead (which includes the clerical, officer, and managerial time with benefits) and immigration benefits provided for free. As a consequence of USCIS immigration fees being based on resource expenditures related to the benefit in question, USCIS uses the fee associated with an information collection as a reasonable measure of the collection’s costs to USCIS. USCIS has established the fee for Form I-601A at $585. The estimated cost of the program to USCIS is then calculated by multiplying the estimated number of respondents by the fee and adding direct overhead costs for forms management. The number of respondents, 52,918, x $585 fee and the $85 biometrics services fee charge is $35,455,060(total cost to the government). The estimated annual overhead cost for printing, stocking, and distributing this form, $2,804.

15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form 83-I.

Data collection Activity/Instru-ment	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
I-601A				52,500	79,377	+26,877
Biometrics				40,950	61,914.06	+20,964.06
Total(s)				93,450	141,291.06	+47,841.06

There has been an increase (47,841.06 annual burden hours) in the annual burden hours previously reported for this information collection. USCIS previously reported 93,450 burden hours and it is now reporting 141,291.06 burden hours. This change can be attributed to a change in USCIS’s estimate for the number of respondents by 9,191 additional respondents submitting this type of request and requesting biometric services (previously estimated 35,000 respondents filing I-601A requests and providing biometrics, while it is now estimates 52,918 respondents filing the form and providing biometrics as well). See table under question 12 for more information.

USCIS has changed the estimated burden of this collection to account for the new applicants who may file this request.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

This information collection will not be published for statistical purposes.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

USCIS will display the expiration date for OMB approval of this information collection.

Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission,” of OMB 83-I.

USCIS does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved with this collection.

File Type	application/msword
File Title	SUPPORTING STATEMENT FOR
Author	TSA Standard PC User
Last Modified By	Miranda-Valido, Liana M
File Modified	2016-05-12
File Created	2016-05-12