G-28 30-Day Public Comment Response Matrix

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Comment #:

Comment:

Comment
ID/Link: 0308
Comment #: 1
Intro/Summary

Comment Author: American Immigration Lawyers Association
On behalf of the American Immigration Lawyers Association, we submit herewith our
comments to the Federal Register 30-day notice, dated September 17, 2024, requesting
additional comments on the proposed revisions to Form G-28/Form G-28I, Notice of
Appearance as Attorney or Accredited Representative.
From attachment:
October 17, 2024
Via Regulations.gov
Department of Homeland Security
U.S. Citizenship and Immigration Services
Office of Policy and Strategy
Regulatory Coordination Division
5900 Capital Gateway Dr.
Camp Springs, MD 20588-0009
Attn: Samantha L. Deshommes,
Chief, Regulatory Coordination Division
Re: Additional Comments to Agency Information Collection Activity: Notice of Entry of
Appearance as Attorney or Accredited Representative, USCIS Forms G-28 and G-28I;
OMB Control Number 1615-0105 e-Docket ID number USCIS-2008-0037
Dear Ms. Deshommes:
The American Immigration Lawyers Association (AILA) respectfully submits the
following supplemental comments in response to the above-referenced Federal Register
30-day notice1 dated September 17, 2024, requesting comments on the proposed revisions
to Form G-28, Notice of Appearance as Attorney or Accredited Representative.
Established in 1946, AILA is a voluntary bar association of more than 16,000 attorneys
and law professors practicing, researching, and teaching in the field of immigration and
nationality law. Our mission includes the advancement of the law pertaining to
immigration and nationality and the facilitation of justice in the field. AILA members
regularly advise and represent businesses, U.S. citizens, U.S. lawful permanent residents,
and foreign nationals regarding the application and interpretation of U.S. immigration
laws. Our members’ collective expertise and experience makes us particularly wellqualified to offer views that will benefit both the public and the government. Our purpose
in writing is to offer comments on each response provided by U.S. Citizenship and

USCIS Response:

No response required.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Immigration Services (“USCIS”) in connection with our initial recommendations to the
proposed revisions to Form G-28/G-28I (hereinafter “Form G-28") as contained in the
supporting document entitled, G-28-010 60-Day Public Comment Matrix (“USCIS
Matrix” or “Matrix”), posted by the USCIS on Sep 16, 2024.2

Comment #: 2
Appreciation

Comment #: 3
General response
to previous
comments and
Burden
Reduction
Initiative

In offering our comments, AILA cites and incorporates fully by this reference its prior
comments on the earlier information collection of July 26, 2023 for the same forms and
we urge USCIS to reconsider adopting them in the revised version of Form G-28.
AILA commends USCIS for Two Changes to the Form G-28

No response required.

AILA applauds USCIS for its decision to allow the limited participation of paralegals in
interacting with the agency on pending immigration benefits requests filed by attorneys.
By permitting a designated paralegal to inquire about case status, request correspondence
or notices, inquire about documents or cards that may need to be replaced, request
appointment accommodations, schedule or reschedule appointments, and request a change
of address, USCIS will help lawyers better serve their immigration clients and thereby
lower the cost of legal services and reduce adjudicative burdens borne by the agency.
AILA is also grateful that USCIS heeded the concerns of numerous commenters and
decided to refrain from requiring attorneys to disclose their date of birth information. By
deciding that the agency would not collect the attorney’s date of birth, USCIS avoided a
needless intrusion into personal privacy, reduced the risks of identity theft, and, in keeping
with the overarching purpose of the Paperwork Reduction Act (PRA), reduced the public
burden hours required to complete Form G-28.
AILA remains concerned about the rejection of comments that would have created several
significant opportunities to reduce the public burden. As the Department of Homeland
Security (DHS) and USCIS recognize, the completion of federal government forms,
especially those prescribed by USCIS, involve public interactions and processes that often
require significant paperwork and time. Specifically, the March 22, 2022, Memorandum
of Eric Hysen, DHS Chief Information Officer, to DHS Component and Office
Heads entitled, Paperwork Reduction Act Burden Reduction Initiative (Hysen Memo)
notes:
 “[The] annual paperwork burden imposed by executive departments and agencies
... on the public has [exceeded] 9 billion hours.”
 DHS alone “imposes over 190 million hours of paperwork burden on the public
each year.”
 “Reducing this burden, and thus eliminating ‘time taxes,’ is a key component of
improving overall customer experience and rebuilding trust in government.”[3]

No response required.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

 “DHS is establishing a target of reducing this public burden by at least 20-millionhours
agency-wide by May 30, 2023 [emphasis in original].
 USCIS’s current burden hours (as of January 7, 2022) were 82,173,255 and were
targeted to be reduced by 8,645,347 burden hours, with a new target of 73,527,908
burden hours by May 30, 2023 – a 10.5% reduction.
While AILA is unaware of whether USCIS met the above-referenced 10.5% target by May
30, 2023, we believe that our recommendations would have further reduced public
burden. The USCIS G-28 Matrix Responses, which contained few or only cryptic
explanations, summarily dismissed several opportunities for reductions in burden hours
that AILA had proposed in our September 25, 2023, initial comments on revisions to
Form G-28.

Comment #: 4
Eliminate Wet
Ink Signatures
and Allow
Digital
Signatures
Response to
USCIS 60-Day
Response and
additional
comments (blue)

[Following paragraph moved from below table to consolidate related content]
AILA’s recommendations referenced above reflect a serious, thoughtful and, from our
perspective, reasonable attempt to enhance the efficiency of Form G-28 for USCIS,
stakeholders and their counsel. As such, it is disappointing that USCIS seems to have
failed to give due consideration to several of our proposals. The sections below will
respond to each of the USCIS Matrix comments noted above and respectfully request that
DHS and USCIS reconsider implementing them or, in the alternative, provide a more
fulsome and considered explanation before Form G-28 is reissued in final form.

30-day Comment:
Eliminate Wet Ink Signatures and Allow Digital Signatures.

USCIS Response: USCIS complies with the
Hysen memo as its regulations at 8 CFR
103.2(a)(2) requires a handwritten signature, but
provides that USCIS may accept electronic
signatures as provided in regulation when
applications are submitted using the USCIS online
filing process. USCIS does not require “wet ink”
signatures for Form G-28 or any immigration
benefit request, as copies of the original
handwritten signature are generally accepted. In
addition, USCIS has recently implemented a PDF
upload process for submission of certain requests
using an online USCIS account.
USCIS continually looks for ways to minimize
burden and streamline its request submission
processes.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

The Hysen Memo stated: Accept electronic or digital signatures. Consistent with the 21st
Century Integrated Digital Experience Act (Pub. L. 115-336), which requires agencies to
accelerate the use of electronic signatures to reduce burden, the Department should avoid
requiring customers to print out, sign, mail and/or fax an official form in order to promote
more equitable and efficient services to the public. (Italics in original; footnotes omitted.)

Comment #: 5
Allow Multiple,
Alternate
Appearances on
Form G-28

Regrettably, USCIS’s matrix response deviates from the unambiguous guidance of the
Hysen Memo’s recommendation to adopt electronic signatures. Rather than
“[accelerating] the use of electronic signatures to reduce burden,” USCIS continues to
require that which the Hysen memo expressly rejects, i.e. requiring “customers to print
out, sign, mail and/or fax an official form.” AILA respectfully requests that USCIS
reconsider our proposal or, in the alternative, provide a more substantive explanation as to
why it chose not “promote more equitable and efficient services to the public” in this
instance.

Response to
USCIS 60-Day
Response and
additional
comments (blue)
Allow Multiple, Alternate Appearances on Form G-28
AILA encourages USCIS to reconsider the benefits of restoring the historic practice of
allowing multiple, attorneys to be listed on a single Form G-28. This was the longaccepted practice at the legacy agency, Immigration and Naturalization Service, and at
USCIS when the form was a single page. While recognizing the need for additional pages
as evolving legal requirements warranted, AILA urges the restoration of this timesaving
and burden-saving option. Permitting multiple attorney registrants in the same law firm
(and for that matter, alternate paralegals in the same law firm as well) to be listed on a
single Form G-28 would streamline agency adjudications and relieve public burden hours.
Reducing the time and burden of unnecessary correspondence to and from the agency and

USCIS Response: Regulations at 8 CFR
103.2(a)(3) provide that a requester may be
represented by an attorney or accredited
representative in the United States. That regulation
does not provide for multiple attorneys or
accredited representatives to simultaneously
represent the requester on the same issue.
Regulations at 8 CFR 103.2(b)(19)(ii)(A) provide
that when a requester is represented, USCIS will
send original notices both to the applicant or
petitioner and their attorney or accredited
representative of record.
If multiple attorneys or accredited representatives
were included on the Form G-28, USCIS would be
required to capture the data on each attorney and
send each of them a notice. That multiple notice
requirement for all benefit requests is overly
burdensome for USCIS to administer. In addition,
validating more than one attorney or accredited
representative as authorized to communicate with
USCIS via the USCIS Contact Center for all

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

the applicant/petitioner and counsel, a key purpose of the PRA, would be better achieved
if multiple lawyers and paralegals could be listed on the same G-28. AILA therefore
renews its request that USCIS amend Form G-28 to reinstate this salutary option.

benefit requests is overly burdensome for USCIS
to administer. Thus, we decline the suggestion to
permit more than one attorney or accredited
representatives per Form G-28.
To add a new attorney or accredited representative,
a new Form G-28 is needed to remove the
previous attorney or accredited representative and
for the client to agree to allow USCIS to share
information under the Privacy Act with the new
attorney or accredited representative.

Comment #: 6
Allow
Designation of
Attorney
Appearances
before DOS on
Form G-28.
Response to
USCIS 60-Day
Response and
additional
comments (blue)

Allow Designation of Attorney Appearances before DOS on Form G-28.
While acknowledging the obvious points that the “State Department is a different cabinet
agency from DHS,” and that “DHS has no authority to govern DOS,” we also note that the
converse is true. DOS has no authority to govern DHS (or the content of its forms).
Having acknowledged the axiomatic, AILA nonetheless urges that USCIS promptly add to
the agenda of regular interagency consultations between DHS and DOS and inquire of
DOS whether consensus can be reached on our recommendation regarding the addition of
a DOS checkbox on the Form G-28.
Adding the checkbox would be consistent with and facilitate the FAM provision, 9 FAM
601.7- 3(c)(2)(a), allowing attorney appearances before U.S. consulates by filing Form G-

USCIS Response:
USCIS recognizes that other DHS components and
Executive Branch agencies have historically used
the USCIS notice of appearance in lieu of creating
their own form. We also recognize that
noncitizens and even many practitioners do not
clearly understand or appreciate the differences
between the immigration functions administered
by USCIS, ICE, CBP, State Department,
Department of Labor, and the Department of
Justice. Nevertheless, the legal authorities and
requirements under which USCIS created Form G28 differ from those of these other components and
agencies. USCIS is willing to explore the creation
of a standard, comprehensive notice of appearance
form for use by all agencies if such an effort is
coordinated by EOP/OMB/OIRA sometime in the
future. However, that effort greatly exceeds what
we can accomplish within the parameters of this
form revision project.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Comment #: 7
Establish a
Notification
Procedure and
Communication
Process for
Rejected G-28s

28, and the requirement directed to attorneys in the Public Inquiry Form of DOS’s
National Visa Center (“Please enter the Attorney of Record's name as it appears on Form
G-28.” It would also further the objectives of the PRA by allowing a straightforward and
approved way for attorneys to disclose to U.S. consular officers their representation of a
particular client in consular visa and citizenship matters. A checkbox of this type would
not intrude on the legal authority of each department’s self-governance but rather foster
public benefits through inter-departmental cooperation.

Response to
USCIS 60-Day
Response and
additional
comments (blue)
Establish a Notification Procedure and Communication Process for Rejected G-28s
In its comments, AILA expressed its recommendation that creation of both a notification
procedure and a prescribed process for communication with the listed attorney (or
accredited representative) as well as the listed benefit requestor on rejected Forms G-28
are essential to secure the requestor’s legal rights and enable the attorney (or accredited
representative) to correct any issues as quickly as possible. Unfortunately, USCIS did not
address AILA’s comments; instead, it simply changed the word “reject” to “will not
recognize” with regard to Forms G-28 submitted without the required
information in Parts 1 and 2. When USCIS does not recognize a submitted Form G-28,
either properly or improperly, it can often take weeks, and sometimes months, to get
USCIS to match up a new Form G-28 with the file. Meanwhile, if the requestor does not
receive USCIS notices (receipt notice, RFE, biometrics notice, interview notice, denial
notice), sometimes because of postal service issues or a transcription error by USCIS of
the requestor’s address, the requestor may lose important legal rights and benefits.

USCIS Response:
DHS regulations provide that where a notice of
representation is submitted that is not properly
signed, the benefit request will be processed as if
the notice had not been submitted. USCIS
receives millions of Form G-28s annually. Our
intake processes are complicated by that volume
and the need to quickly and efficiently receive
requests and assign them for adjudication. An
additional inadequate Form G-28 communication
process would delay intake and add a process for
which USCIS would be required to pay the
Lockbox contractor. USCIS would not be able to
recover those costs until DHS published a new fee
rule. Finally, it is important that USCIS not
communicate with someone about a case to which
they are not a party. Thus, we plan to make no
changes in this area at this time. Meanwhile,
USCIS recommends that practitioners double
check their Form G-28s to make sure they do not
contain minor errors that render them inadequate.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Comment #: 8
Establish a
Centralized
Online USCIS
Portal to Record
Attorney
Appearances/Wit
hdrawals.
Response to
USCIS 60-Day
Response and
additional
comments (blue)

As stated in our previous comment, AILA believes that creation of both a notification
procedure and a prescribed process for communication with the listed attorney (or
accredited representative) and the listed requestor on rejected Forms G-28 are essential so
that an attorney (or accredited representative) may quickly correct and resubmit the Form
G-28 if it is not accepted at the time of filing, and ensure that the requestor’s legal rights
are not adversely affected. Accordingly, we respectfully request that USCIS reconsider
AILA’s recommendation.

USCIS Response:
USCIS has already built functionality for a Form
G-28 to be withdrawn through a USCIS online
account. When using the online account option, an
attorney or accredited representative does not need
to send the request to the office that has the case,
eliminating the need to track the movement of the
case.
Additionally, USCIS is actively updating the
online user experience for Form G-28 filing,
interaction, and processes to make additional
enhancements.
USCIS will take development of an immigration
practitioner registry into consideration as part of
future technology builds.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Establish a Centralized Online USCIS Portal to Record Attorney
Appearances/Withdrawals.
In rejecting AILA’s proposal that USCIS create an online centralized system for the entry
of appearances and withdrawals of attorneys as counsel of record in immigration-benefits
requests, the USCIS Matrix response expressed that “DHS appreciates the suggestion . . .”
Nonetheless, DHS and USCIS declined the invitation, asserting that “an immigration
practitioner registry exceeds what we can do through a form revision under the Paperwork
Reduction Act.”
As interpreted by the DHS’s Chief Information Officer, however, the PRA empowers
agencies to create online systems for burden reduction and time savings. On this point, the
Hysen Memo stated: Enable online submission of all forms, where appropriate. Wellimplemented online forms can reduce burden and save time. They can enable the public to
access and complete forms through improved guidance, error checking, simplified
navigation, and accessibility improvements, thereby creating a more efficient process.
(Italics in original.)
While acknowledging that our proposal would be an undertaking requiring additional
development time and effort, we believe the Hysen Memo effectively endorses and, in
fact, encourages the creation of an online centralized system for attorneys to enter
appearances or withdraw as counsel of record in matters before the agency.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

To amplify the PRA-related benefits of our proposal, AILA members’ collective
experience confirms that the current USCIS system for attorney appearances and
withdrawals is not an efficient process. The paper-based, mail-in system for entering and
withdrawing attorney appearances is fraught with dysfunctionalities. For example: (a)
USCIS frequently and with little advance notice changes the place for filing particular
immigration benefits requests, thereby leading to misdirected filings, and (b) the entry of
withdrawals of representation depends on the at-times unknown or undisclosed USCIS
field office or service center that then possesses the benefit request, a process made even
more challenging by the agency’s practice of transferring case types between and among
its offices to conduct in-person interviews or balance adjudication workloads.
AILA’s members also find the online entry of an attorney appearance in myUSCIS
similarly problematic. For example, AILA has been advised that, in a benefits request
where a lawyer has already entered an appearance but in fact has resigned from
representation, substitute counsel cannot make an appearance through myUSCIS unless
and until prior counsel has withdrawn from representation in myUSCIS.
The adoption of a centralized online system to record attorney appearances and
withdrawals would also unburden USCIS and foster the PRA’s goals due to the fact that
the agency would no longer be required to provide official correspondence to a lawyer
who (unbeknownst to a particular adjudicator) has already withdrawn, or to deal with the
inevitable requests and motions of successor counsel seeking a duplicate of official
correspondence (such as a request for evidence, notice of intent to deny or revoke, denial
notice, or notice to appear for interview, naturalization ceremony, etc.) sent to prior
counsel. AILA therefore respectfully requests that USCIS reconsider our recommendation
that it create an online centralized repository and portal to register appearances and
withdrawals of attorneys as counsel of record in matters before the agency.
We renew this recommendation, along with our previously restated recommendation to
allow the listing on a single Form G-28 of multiple alternate attorneys and paralegals in
the same firm, because we believe they will reduce burden hours on the agency and
immigration stakeholders, in keeping with the bedrock objectives of the PRA.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Comment #: 9
Expressly Allow
for Limited
Appearances and
Limited Scope
Representation.

USCIS Response:
Each USCIS form contains a section for preparers
to complete. After reviewing 8 CFR 1.2 definitions
of practice and preparation, and their state bar
rules related to practice, an attorney may limit their
representation to preparer by completing the
preparer section on the immigration benefit form
without filing a Form G-28. In addition, an
attorney may submit a separate Form G-28 for the
limited purpose of attending an interview with a
temporary client as a substitute for a colleague.

Response to
USCIS 60-Day
Response and
additional
comments (blue)

Expressly Allow for Limited Appearances and Limited Scope Representation.
AILA is heartened that USCIS’s Matrix response agreed with our September 25, 2023,
comment to the earlier version of the proposed Form G-28, namely, by acknowledging
that the agency “already permits some limited scope representation, such as to attend an
interview with an applicant who the attorney has otherwise not been representing on their
benefit request.” Yet USCIS then asserted that “[further] clarification of limited scope
attorney-client relationships is beyond the scope of the proposed G-28 revision and would
also require a regulatory change/changes.” The legal basis for this statement, i.e. that
regulatory changes are necessary to further clarify or limit the scope of attorney
representation, is unclear to AILA as it is already permitted by USCIS in several instances,
such as paralegal representation, limited scope representation for interviews, and on Form
I-485, item 7.B (see below).

USCIS created Forms G-1593 and G-1594 which
permit attorneys and accredited representatives to
appear remotely for credible fear interviews and
we are considering expanding it for other remote
interviews. Last, attorneys and accredited
representatives may voluntarily withdraw from
representation at any point in the representation.
USCIS declines to create additional limited
appearances.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Can USCIS further clarify its justification so that AILA can provide further
recommendations on this issue in the future?
AILA poses these issues not to question the appropriateness of these forms of limited
representation (on the contrary, we agree with them) but rather to illustrate that the
agency’s well-established pattern and practice of allowing limited appearances and limited
scope representation has occurred without formal rulemaking. We also believe that the
current USCIS practice which informally allows the unbundling of legal services, through
limited scope representation and limited appearances, without expressly recognizing their
legitimacy, undermines the goals of the PRA, contrary to the public interest.
As the American Bar Association has noted in its “Unbundling Resource Center”:
Unbundling, or limited scope representation, is an alternative to traditional, fullservice
representation. Instead of handling every task in a matter from start to finish, the lawyer
handles only certain parts and the client remains responsible for the others. It is like an à
la carte menu for legal services, where: (1) clients get just the advice and services they
need and therefore pay a more affordable overall fee; (2) lawyers expand their client base
by reaching those who cannot afford fullservice representation but have the means for
some services; and (3) courts benefit from greater efficiency when otherwise selfrepresented litigants receive some counsel. (Emphasis added.)
Just as the courts benefit from greater efficiency when otherwise self-represented litigants
receive some counsel, AILA believes that USCIS and immigration stakeholders would
similarly benefit if the agency were to modify the Form G-28 and expressly recognize
alternative limited appearance options in addition to those the agency already permits.
AILA therefore urges that USCIS amend Form G-28 to allow for limited scope
representation and limited appearances as proposed in our comments of September 25,
2023, at pp. 9-13.

Form G-28-010 Revision Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2008-0037
60-day FRN Citation (federalregister.gov): 89 FR 76126
Publish Dates: September 17, 2024 – October 17, 2024

Comment #: 9
Conclusion and
citations

AILA appreciates the opportunity to submit its additional comments urging the adoption
of significant improvements to Form G-28 as proposed in this letter and we look forward
to a continuing dialogue with USCIS on this important matter.
Respectfully submitted,
AMERICAN IMMIGRATION LAWYERS ASSOCIATION
1 89 FR 76126-76127, September 17, 2024.
2 All hyperlinks last accessed on October 17, 2024.
3 See also Report, “Tackling the Time Tax [~] How the Federal Government Is Reducing
Burdens to Accessing Critical Benefits and Services,” Executive Office of the President,
July 2023, accessible here: https://www.whitehouse.gov/wpcontent/uploads/2023/07/OIRA-2023-Burden-Reduction-Report.pdf.
4 AILA offers another example where USCIS on acknowledged the de facto practice of
limited appearances in the absence of formal rulemaking, indeed, in a situation that prima
facie flouts a specific rule, 8 CFR § 292.3 (prescribing disciplinary proceedings against a
lawyer who consistently violates the requirement to file a G-28). It involves the agency’s
policy statement (last updated on February 18, 2011) announcing that DHS will refrain
from disciplining lawyers who are otherwise reluctant to submit a G-28 “based solely on
the failure to submit a Notice of Entry of Appearance as Attorney or Accredited
Representative (Form G-28) in relation to pro bono services provided at group assistance
events,” accessible at: https://www.uscis.gov/archive-alerts/statement-of-intent-regardingfiling-requirement-for-attorneys-and-accreditedrepresentatives.
5 The problems with the current USCIS practice whereby limited appearances and limited
scope representation are allowed but not expressly or widely recognized are described in
detail by Catholic Legal Immigration Network, Inc. (cliniclegal.org) in its “Practice
Pointer: Limited Assistance to Noncitizens with USCIS Applications,” accessible
here: https://www.cliniclegal.org/file-download/download/public/75357.

No response required.