30-Day Comment Response Matrix

Form I-765-050 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2005-0035-0201
30-day FRN Citation (federalregister.gov): 89 FR 57159
Publish Dates: July 12, 2024 – August 12, 2024
Comment #/Topic
1.

Commenter ID

Comment
Commenter: jean publie

USCIS Response
USCIS-2005-0035-0
202.pdf

USCIS-20050035-0202

2.

none of these foreign liars and sneaks shoudl get
one penny of american tax dollars. alll of them
need to be stopped at the border and if they get
through find them and deport them immediately
when found. none of them are worth being in the
usa. the real victims of trafficking are the us
citizens who are eing bankrupted to pay for thesee
foreign leaches who belong in their own country
instead of sneaking all over there to get leaching
on us citizens. stop the bankurupting of american
citizens for these sneaking leaches from foreign
countries. send them home to their rotten
countries.they are making america into the they
came from.
Commenter: Justice at Work Pennsylvania

Response: The commenter expressed an
opinion on immigration issues generally.
USCIS is making no changes to the form or
instructions as a result of this comment.

USCIS-2005-0035-0
209_attachment_1.pdf

USCIS-20050035-0209

The two-page letter submitted by Justice at Work
Pennsylvania acknowledges the efforts of USCIS
has undertaken form updates to support the final
T rule, specifically mentioning the updates to
USCIS Form I-765.
“We write in support of changes made to the I765, particularly the added instructions on Page

Response: Thank you for your comment.
The commentor did not request any specific
changes to any forms with their comments.

Form I-765-050 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2005-0035-0201
30-day FRN Citation (federalregister.gov): 89 FR 57159
Publish Dates: July 12, 2024 – August 12, 2024
14, Number 10. 8 CFR 214.11(e) allows for bona
fide determinations in T nonimmigrant status
applications, and 22 USC §7105(b)(1)(E)(II)(aa)
demonstrates congress’ intention that federal
benefits can be granted if an application for a visa
is bona fide.
The importance of these determinations is majorly
important for our clients who have survived
trafficking, as the ability to work and receive
certain public benefits is an essential part of their
financial, physical, and mental recovery from their
trafficking experiences.
We further appreciate the clarity surrounding
applicants who have already filed for an
Employment Authorization Document with Form I914. We believe this instruction will reduce
unnecessary extra steps and barriers for our
clients.”
Commenter: Anonymous

3.

USCIS-2005-0035-0
210.pdf

USCIS-20050035-0210

There are some ways that, in my opinion, that I765 could be made more friendly for transgender
(and others who have changed their gender)
individuals.

Response: This comment suggests a change
that is not related to the information
collection requirements made in the USCIS T
nonimmigrant Final Rule so it will not be
adopted at this time. However, USCIS is

Form I-765-050 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2005-0035-0201
30-day FRN Citation (federalregister.gov): 89 FR 57159
Publish Dates: July 12, 2024 – August 12, 2024
The first is with the "Other Names Used" question.
Other people, in the past when this form has had a
comment period, have questioned whether or not
such an inquiry is actually needed here. Since
requiring transgender applicants to disclose
former names generally means they're effectively
being forced to out themselves, I think the
practice of asking for all other names ever used
needs to be re-evaluated (especially if asked in a
matter where a private employer would see such
names).
The second is providing a non-binary option for
the "Gender" question.
The third is with the question about the parents'
names - consider a gender-neutral "Parent"
instead of "Father" and "Mother" in the inquiry
(also helpful for those who may have two samegender parents).
The fourth also deals with the same questions as
the third, when you ask for the parents' "birth
name" (which like the first issue requires providing
a name that is likely to be indicative of the
parent's gender change). If the intent is to capture
what the parent's name would be without
accounting for any marriage-related name
changes, then consider rephrasing the question so
an applicant with a trans parent can use the first

making changes that are as the commenter
suggests in an ongoing Form I-765 revision
project that should be completed in a few
months.

Form I-765-050 Revision - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2005-0035-0201
30-day FRN Citation (federalregister.gov): 89 FR 57159
Publish Dates: July 12, 2024 – August 12, 2024
name that matches their gender identity. If the
intent is to match how the parent's name appears
on the applicant's birth certificate, then likewise
consider asking for such specifically (since birth
certificates in many jurisdictions can be amended
to reflect a name/gender change).