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Supporting Statement A
ICR 202609-1653-001 · OMB 1653-0038 · Object 174091300.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
|---|---|
| File Title | Supporting Statement A |
| Author | Villafana, Maria F |
| Last Modified By | Writer |
| File Modified | 2026-10-21 |
| File Created | 2026-11-05 |
| Conversion State | complete |
Extracted Text
Supporting Statement
Student and Exchange Visitor Information System (SEVIS)
Forms I-17 and I-20
Office of Management and Budget (OMB) No. 1653-00381
Justification.
1. Explain the circumstances that make the collection of information necessary.
The Student and Exchange Visitor Information System (SEVIS) is a web-based system used to collect and maintain information on F and M nonimmigrant students during their stay in the United States. The system also facilitates the Student and Exchange Visitor Program’s (SEVP) certification of educational institutions to enroll F and M nonimmigrants.
The authority to collect the information in SEVIS, along with the accompanying Forms I-20, “Certificate of Eligibility for Nonimmigrant Student Status,” and Forms I-17, Petition for Approval of School for Attendance by Nonimmigrant Student,” is codified at 8 U.S.C. 1372. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA)2 mandated the creation of an electronic system to collect data on F and M nonimmigrant students and the schools they attend. Subsequent laws, such as the USA PATRIOT Act of 20013 and the Enhanced Border Security and Visa Entry Reform Act of 2002 (EBSVERA)4, added data collection requirements for F and M nonimmigrants and SEVP-certified schools. The Homeland Security Presidential Directive-2 (HSPD-2) required DHS to conduct periodic and ongoing reviews of all SEVP-certified schools.
All data collection requirements for reporting on F and M nonimmigrant students and the SEVP certification, oversight, and recertification of schools authorized to enroll F and/or M students as mandated by laws and directives are contained in regulations at 8 CFR 214.1, 8 CFR 214.2(f) and (m), 8 CFR 214.3,8 CFR 214.4. 8 CFR 214.13, 8 CFR 103.3 and 103.7, 8 CFR 248, and 8 CFR 274a.12.
2. Indicate how, by whom, and for what purpose the information is to be used.
SEVP uses SEVIS to administer education institutions’ certification to enroll F and M nonimmigrant students. Education institutions seeking SEVP certification or recertification must complete and submit the Form I-17, which contains information about the institution, including its programs of study, campus locations, and designated school officials (DSOs) authorized to access SEVIS. The Form I-17 also contains the SEVP-certified school’s legally binding commitment to comply with all applicable federal laws, regulations, policies, and procedures.
DSOs use SEVIS to maintain the school’s Form I-17 and provide information on the F and/or M nonimmigrants studying at their school to comply with regulatory recordkeeping and reporting requirements. Specifically, DSOs complete and issue the Form I-20. The Form I-20 is used to apply for a U.S. visa to study as an F or M student, to be admitted into the United States, and to apply for employment benefits. Eligible F and M nonimmigrant students may also use the SEVP Portal, a subset of SEVIS,5 to submit updated personal and employment data directly to DHS.
Law enforcement agencies use SEVIS to protect national security and enforce immigration laws. SEVIS is a critical national security component and a primary resource for conducting counterterrorism and counterintelligence threat analysis by the law enforcement and intelligence communities. The system is used daily to qualify individuals for F and M status and to facilitate:
• Port-of-entry admission screening.
• Processing of nonimmigrant benefit applications.6
• Verification of nonimmigrant status maintenance.
• Timely removal of nonimmigrants from the United States, as needed.
SEVIS data is used to assist school officials and the United States government in promoting the Secure Borders and Open Doors initiative (January 17, 2006). In concert with biometric assessment technologies, SEVIS data continues to support access to the United States for bona fide aliens seeking F and M nonimmigrant status, while elevating the detection and barring of aliens that might threaten national security.
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 to adopt this means of collection. Also describe any consideration of using information technology to reduce burden.
The collection of information for SEVIS involves extensive use of automated, electronic, and other technological collection techniques. SEVIS allows for the electronic submission of responses and information, replacing the previously complex, decentralized, and inefficient paper-based processes.
Key Technological Features:
• Electronic Data Entry: SEVIS enables DSOs to enter and update information electronically, ensuring data is collected uniformly and is immediately accessible to authorized users.
• Automated Notifications: SEVIS supports automated email notifications to DSOs and certain nonimmigrant students, providing timely information and reducing the need for traditional paper-based communication.
• Electronic Forms: Since August 1, 2003, all data must be entered in SEVIS, and all forms, including Forms I-17 and I-20, must be generated through SEVIS, eliminating the need for multiple copies of forms and streamlining the process.
• Paperless Procedures: SEVP has instituted paperless procedures for the service of notices and adjudications to schools and requires electronic submissions of Form I-17, which can include uploading scanned or electronically signed Form I-17. When available or requested, DSOs can upload supporting documents via SEVIS to support management of the school certification and the F and M student records. Additionally, SEVP has allowed for electronic signatures and transmission of Form I-20 and plans on fully automating the Form I-20 process.
• Enhanced Reporting Capabilities: SEVP has invested in enhancing SEVIS reporting capabilities, allowing for refined data analysis and better oversight of school compliance. These enhanced reporting capabilities also support the identification of performance trends and policy needs. SEVP will be updating the Form I-17 and Form I-20 fields to streamline DSOs reporting and improve the data integrity within the system. These enhanced reporting capabilities include facilitating extension of stay process for F nonimmigrants and updating program information fields.7
• Student Portal: DHS has implemented the SEVP Portal, enabling students to submit personal and employment information directly to DHS, reducing the reporting burden on DSOs. Currently, the portal is limited to F-1 students participating in post-completion optional practical training or the science, technology, engineering and mathematics (STEM) extension of OPT, with plans to expand its use in the future.
• Facilitation of on-site visits: The information collected on Form I-17 supports on-site visits8 of school petitioning for certification to enroll F and M students.
Consideration of Using Information Technology to Reduce Burden:
• Reduction of Manual and Paper Processing: The use of SEVIS significantly reduces manual and paper processing by both DHS and school personnel, leading to cost savings and improved efficiency.
• Minimized Recordkeeping Burden: SEVIS data and the information uploaded through SEVIS is retained indefinitely in electronic form, reducing the need for schools to retain paper copies of records.
• Improved Data Integrity: The electronic system contributes to the timeliness and integrity of data, with a resulting positive impact on other federal systems that interact with SEVIS.
• Cost Savings for Schools: The elimination of paper forms and the use of electronic validation reduces the costs associated with postage, handling, and the impact of potentially fraudulent documentation.
• Minimize DSO Reporting Burden: The Student Portal allows DSOs to shift reporting of certain information to the F student.
4. Duplication of collection.
SEVP has made efforts to identify and eliminate duplication in the collection of information related to F and M nonimmigrants and SEVP-certified schools. The data collected through SEVIS is highly specific and mandated by various laws, including IIRIRA, the USA Patriot Act, and EBSVERA. These mandates require continuous and detailed data collection that is unique to SEVIS. A comprehensive analysis of existing data systems confirmed that no other system collects the same specific information required for SEVIS. While several systems complement SEVIS by collecting generic data on aliens, they do not provide the ongoing academic and compliance data needed for SEVIS operations.
To further reduce duplication, SEVP has developed interfaces with other government data systems, allowing for relevant data sharing while ensuring SEVIS-specific requirements are met. Despite these interfaces, SEVIS remains unique in its ability to capture and manage real-time updates on student status and school compliance.
5. Impact on small business or any other small entities.
The collection of information through SEVIS does impact small businesses and other small entities, particularly SEVP-certified schools. To minimize this burden, SEVP leverages existing technology and requires schools to only have internet access to use SEVIS, with no additional software needed9. The transition to electronic form submissions and paperless procedures has reduced the administrative costs associated with traditional paper-based processes. Streamlined data entry processes have significantly reduced the time required to submit SEVIS updates, and SEVP provides training and support to help small entities comply efficiently. Although the fee structure associated with school certification and the use of SEVIS applies uniformly to both large and small entities, it is designed to balance costs with the revenues schools typically accrue by enrolling F and M students. These measures ensure that the information collection requirements are manageable and do not impose an undue burden on small entities.
6. Consequence to the federal program or policy activities if the collection is not conducted or is conducted less frequently.
If information is not collected in SEVIS, DHS will not be able to comply effectively with the statutory mandates of legislation cited in Item 1. Information would need to be collected through a paper process, as previously required, which would most likely necessitate resumption of manual data entry and create a backlog for data entry. The data integrity of the F and M nonimmigrant information may also be compromised. DHS measures to ensure compliance with the law and regulations will be severely limited without the information being retained and without it being as readily accessible as it is in SEVIS. Collection of data less frequently than is required by SEVP could result in failure to make timely identification of potential F and M nonimmigrant threats to national security or threats of immigration fraud.
7. Explain special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.
The collection of information through SEVIS involves several special circumstances that necessitate deviations from standard OMB guidelines:
• Reporting More Often Than Quarterly: Respondents are required to report information more often than quarterly due to the need for timely updates on student enrollment, personal information, address changes, and visa status maintenance. This frequent reporting is essential to promptly identify and address potential threats to national security or immigration fraud (8 CFR 214.2(f)(17) and 8 CFR 214.2(m)(18)).
• Written Responses in Fewer Than 30 Days: In specific circumstances, such as changes in student status or school compliance, respondents must prepare and submit written responses within 30 days or less. This expedited timeline ensures that enforcement agencies receive timely information to mitigate potential security risks or instances of noncompliance (8 CFR 214.3(g)).
• Retention of Records for More Than Three Years: Schools are required to retain student records for at least three years after program completion or transfer to another school. This extended retention period is necessary to ensure compliance with federal regulations and to facilitate audits and reviews of student and school compliance.
These special circumstances are necessary to meet the statutory and regulatory requirements for monitoring and managing F and M nonimmigrant students and SEVP-certified schools, ensuring timely and accurate data collection to support national security and compliance efforts.
8. Solicitation of public comments.
The Notice of Proposed Rulemaking titled Optional Practical Training Fees, RIM 1653-AB01, was published on 08 October 2026 in the Federal Register, Volume 91, page 64566.
9. Explanation of payment or gift to respondents.
SEVP does not provide payments or gifts to respondents for this information collection.
10. Assurance of confidentiality.
DHS has designated SEVIS to be a Privacy Act system of records and SEVIS information will be used and disclosed in accordance with 5 U.S.C. §552a, Privacy Act of 1974, as amended. SEVP published a Privacy Impact Assessment Update10 on February 20, 2020. The most current System of Records Notice (SORN)11 was published on December 8, 2021.
There is no assurance of petitioner confidentiality associated with appeal or motion proceedings related to SEVP certification. SEVP will use the information submitted to determine eligibility for the benefit. SEVP may provide information on the form to other government agencies.
11. Justification of questions of a sensitive nature.
There are no questions of sensitive nature asked in this information collection.
12. Annual and one-time public reporting burden and public cost.
SEVP certifies qualifying schools and grants them access to SEVIS. DSOs at these SEVP-certified schools are their primary respondents. As employees of the SEVP-certified schools, DSOs collect and enter the information required in SEVIS through their school’s own admission information collection tools. That data is used to populate the SEVIS Forms I-17 and the Forms I-20 identified in Item 2 of this supporting statement; DSOs carry nearly all their school’s reporting burden (F and M nonimmigrants do not currently have a reporting burden, as identified in this supporting statement).
One-Time Public Reporting Burden and Public Cost
There is a one-time burden associated with this collection of information. SEVP will be redesigning the “Program of Study” page on the I-17 Form. DHS estimates that this change will impose a burden that will be borne by DSOs to enter program information into the new program of study page. DHS estimates that entering program information into the new page will require approximately one hour of time from a DSO at each of the 6,778 SEVP-certified schools. At $50.04 per hour for 6,778 hours, the one-time cost for entering program information into the new Program of Study page will be $339,171.
Management of school information – one-time costs12
SEVP-certified Form I-17 school information
Number
Frequency
Burden (hours)
Subtotal (hours)
Cost/hr.
Subtotal ($)
SEVP-certified schools
6,778
Redesign of the program of study page
6,778
1
1
6,778
$50.04
$339,171
Total hours
6,778
Total cost
$339,171
Annual Public Reporting Burden and Public Cost
This collection information also has ongoing annual public reporting burdens. The ongoing annual public reporting burden is borne by DSOs through:
• Collecting F-1 and M-1 student information in their school’s admission information collection tools and with their processes.
• Collecting, updating recertification and managing F and M nonimmigrant information in SEVIS.
• Managing their respective school’s SEVP certification, including initial certification, compliance.
• Updating SEVIS with information relating to payment confirmation of applicable OPT fees
The ongoing public cost is borne by SEVP-certified schools through:
• Paying salaries of DSOs while engaged in reporting to SEVP.
• Paying fees for SEVP certification and recertification to be authorized to enroll F and/or M nonimmigrant students.
The following table summarizes the combined annual public reporting burden and cost of schools. Greater explanation of this summary and the net cost to the respondents is presented in the text that follows.
Combined summary of annual public reporting burden and cost based on calendar year (CY) 2025 data: student and school records13
Type of information collection
Form
Number of respondents
Number of responses per DSO
Total annual burden (hours)
Cost (hourly)
Total annual cost
A. Management of student records
1. Form
I-20 –
Routine
20,890
DSOs
1
560,979
$50.0414
$28,071,390
2. Form
I-20 – off-campus and OPT employment
20,890
DSOs
1
16,021
$50.04
$801,686
3. Form
I-20 – STEM OPT
20,890
DSOs
1
14,746
$50.04
$737,876
Subtotal - student data
591,746
$50.04
$29,610,953
B. Management of school data
1. Form I-17 SEVP certification/
updates/ recertification
20,890
DSOs
1
302,36115
$50.04
$15,130,136
2. SEVP certification fees
112 Schools
$3,000 + $655 x 2 (site visits)
$482,720
3. Recertification fees
3,000 schools
$1,250 + $655 x 0.5 (site visit)
$4,732,500
Subtotal – school data
302,361
$20,345,356
Total student and school data
894,106
$49,956,309
Annual burden of reporting: collection, updating, and management of prospective and continuing F and M nonimmigrant data by DSOs in SEVIS, based on Aug 2025 data unless otherwise noted, projected for each year CY 2025-2027
The management of student data by DSOs in SEVIS includes the issuance of Forms I-20; gathering, updating, and reporting student information; and the correction of identified errors in student information.
• The 3-year average number of active student records in SEVIS is estimated to total 1,179,028 for each year.16
• SEVP anticipates that an average of 499,421 initial F-1/M-1 students will enroll at SEVP-certified schools annually. Typically, applicants will apply to more than one school, requiring development of an average of 2.5 Forms I-20 per applicant.
• For approximately 35 percent of these, the data will be loaded using real-time interface RTI17 procedures, at 33 minutes (0.55 hour) each to complete. At $50.04 per hour for 240,346 hours, the cost for RTI-loaded initial Forms I-20 will be $12,026,908.
• For approximately 65 percent of these, the data will be loaded using batch procedures, at one minute (0.017 hour) each to complete. At $50.04 per hour for 13,526 hours, the cost for batch-loaded initial Forms I-20 will be $676,841.
• DSOs must update Form I-20 information on students on an ongoing basis. These updates can be for several reasons but, because the data fields populated during initial Form I-20 loading are pre-populated for updates, the update using RTI method is approximately seven minutes (0.117 hour). The update time is two minutes (0.033 hour) using the batch method. On average, students receive four updates to their records annually. An estimated 35 percent of updates will be RTI, at an average annual cost of $9,636,436; 65 percent of updates will be batch, at an average annual cost of $5,113,207.
• SEVP anticipates the 3-year average of active F-2/M-2 dependent records in SEVIS to be 117,531 and anticipates 30,670 initial F-2/M-2 dependent records each year. Each dependent requires an individual Form I-20. Most data on the dependent initial Form I-20 are derived and pre-populated from the data in the principal’s record, so each dependent Form I-20–whether for initial issue or an update–takes five minutes (0.08 hour) to complete. A dependent averages one update per year. The annual aggregate cost for dependents is $617,998.
• For students applying for off-campus employment or OPT, DSOs must provide United States Citizenship and Immigration Services (USCIS) a recommendation for this employment and evidence substantiating the student’s eligibility for the benefit to enable adjudication of application. This information is submitted using Form I-20. SEVP estimates the average number of students applying for off-campus employment or OPT at 142,47118 and each recommendation will require about seven minutes. For students recommended off-campus or OPT employment, the cost is $831,745.
• SEVP anticipates that an average of 84,736 students will apply for STEM OPT.19 DSOs have the additional burden to make a recommendation update to the student SEVIS record. Each recommendation will require about seven minutes. For students recommended for STEM OPT, the additional annual cost will be $494,689.
• SEVP anticipates 226,000 fee payments and 5 minutes for DSOs to confirm payment information in SEVIS.
• The total cost for management of student data is $30,342,958.
Management of student data20
F-1/M-1 student forms I-20 and personal info.
Total
Frequency
Burden (hours)
Subtotal (hours)
Cost/hr.
Subtotal ($)
Active F-1/M-1 students
1,179,028
Initial F-1/M-1 students
499,421
Initial Forms I-20 (RTI)
174,797
2.5
0.55
240,346
$50.04
$12,026,908
Initial Forms I-20 (batch)
324,624
2.5
0.017
13,526
$50.04
$676,841
Updates (RTI)
412,660
4
0.117
192,575
$50.04
$9,636,436
Updates (batch)
766,368
4
0.033
102,182
$50.04
$5,113,207
Off-campus and OPT employment
142,47121
1
0.117
16,622
$50.04
$831,745
STEM OPT
84,73622
1
0.117
9,886
$50.04
$494,689
Active F-2/M-2 dependents
117,531
Initial F-2/M-2 dependents
30,670
F-2/M-2 Forms I-20 initial and update
148,201
1
0.083
12,350
$50.04
$617,998
OPT Fee payment confirmation
226,200
1
0.083
18,850
$50.14
$945,138
Total Hours
611,649
Total Cost
$30,342,958
Annual burden of maintain school information by DSOs in SEVIS, based on Aug 2025 data, projected for each year CY 2025-CY 2027
• The maintenance of school information by SEVP-certified schools includes the initial certification, periodic recertification, and updates (i.e., on-request submission of Forms I-17, reporting of changes, and correction of identified errors).
• Computed costs include expenses incurred by SEVP-certified schools and the time spent entering data and submit reports.
• It does not incorporate costs that may be placed on schools to acquire and maintain equipment for SEVP-related activities.
• For Aug 2025, there were 6,77823 SEVP-certified schools. SEVP anticipates an average of 112 schools to petition for initial certification annually in each of the next three years.
• On average, a DSO at a school will need approximately three hours to complete an initial petition for SEVP certification, to include obtaining access to SEVIS, data entry and the SEVP site visit, 112 schools x 3 hours each = $16,813, aggregate cost.
• An average of 50 percent of the 6,778 schools, or 3,389 schools, will provide two updates to their SEVIS school information annually. Updates to school information will average five minutes (0.08 hours) each, for 565 hours and an aggregate cost of $28,264.
• An average of 3,000 schools will petition for SEVP recertification annually. A principal DSO at a school petitioning for recertification will need approximately 3 hours at an aggregate annual cost of $450,360.
• All documents necessary for the initial petition and recertification are collected electronically.
• SEVP estimates DSO DHS-related personal development (e.g., training, research, reports, and professional development) at 14 hours per DSO annually, 20,890 DSOs x 14 hours = 292,460 total hours at an aggregate cost to schools of $14,634,698.
• The total cost for management of school information is $15,130,136.
Management of school information24
SEVP-certified Form I-17 school information
Number
Frequency
Burden (hours)
Subtotal (hours)
Cost/hr.
Subtotal ($)
SEVP-certified schools
6,778
1. Initial school certification
112
1
3
336
$50.04
$16,813
2. Updates to Form I-17 school information
3,389
2
0.083
565
$50.04
$28,264
3. School recertification
3,000
1
3
9,000
$50.04
$450,360
4. DSO professional development.
20,890
1
14
292,460
$50.04
$14,634,698
School Data Total hours
302,361
Total cost
$15,130,136
13. Capital startup and ongoing equipment costs. 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).
There were no capital or startup costs charged to the respondents or record keepers as a result of the initiation of this collection of information (i.e., the government cost to initiate this collection was not passed on to the schools or the F and M nonimmigrants). Development costs for SEVIS and the initial implementation of SEVP were underwritten with appropriated funds. Recurring maintenance and further development costs are funded by prospective F-1 and M-1 students in conjunction with their payment of the I-901 SEVIS fee, Fee Remittance Form for Certain F, J and M Nonimmigrants (OMB 1653-0034).
Schools that wish to enroll F and/or M students must receive SEVP certification. The initial certification fee is $3,000 for the petition and $655 for site visit for each campus (an average of 2 campuses per petition). For 112 schools anticipated to file for initial certification annually, the aggregate fee for each year will be $482,720.
All SEVP-certified schools must receive recertification every two years. The recertification petition fee is $1,250 and $655 for each site visit (new locations, average 0.5 per school). Over the next three years, an average of 3,000 schools will be recertified annually, for an aggregate annual fee of $4,732,500.
14. Annual government burden and cost.
The total cost projection for SEVP for fiscal year (FY) 2025 to 2027 is estimated to be $186,610. This is based on the budget overview for the Student and Exchange Visitor Program in FY 2024 and FY 2025.25
As a fee funded entity, there is no net ongoing cost to the federal government for SEVP and SEVIS. SEVP is mandated by law to be fully fee-funded (see Item 1). Section 286(m) of the Act, 8 U.S.C. 1356(m), provides that fees must be set at a level that will ensure the recovery of all costs of providing adjudication services. That section, together with Title V of the Independent Offices Appropriations Act of 1952, 31 U.S.C. 9701, and the OMB Circular No. A-25, Revised requires that a fee be set at an amount enough to recover the full cost to the federal government. Fees are developed at a level projected to cover the aggregate of SEVP operating costs. Expenditures are restricted from exceeding the actual amount of revenue received.
Section 641 of IIRIRA, 8 U.S.C. §1372, in directing DHS to collect information relating to academic nonimmigrant students (F-1) and vocational nonimmigrant students (M-1), as well as their accompanying dependents (F-2 or M-2), also provides for the collection of a fee to cover the costs of this program. Through the Form I-901, Fee Remittance for Certain F, J and M Nonimmigrants, (OMB #1653-0034),26 SEVP collects its fees. The Form I-901/fmjfee.com website used for payment of the fee also provides necessary payment verification (electronic receipt) to the prospective F-1 or M-1 student for presentation at their consular interview to obtain their visa.
The respondents to the Form I-901 are the prospective F-1 and M-1 students. The fees collected from them support the Form I-901/FMJ fee site activities and all other facets of SEVP, including SEVIS.
15. Change in burden hours and cost.
Respondents in SEVIS are the DSOs. The DSOs input data into SEVIS in order to fulfill two responsibilities: the management of their school’s F and M nonimmigrant data, and the management of their school’s SEVP certification. Requirements and processes for management of this data have not changed.
This information collection has been revised to reflect changes stemming from the Optional Practical Training Fees NPRM. The NPRM requires DSO to report payment confirmation for applicable OPT fees. In the NPRM, DHS provided new estimates on the number of students participating in OPT and STEP OPT. Payment confirmation will utilize an existing field in SEVIS related to OPT participation. DHS anticipates DSOs will take 5 minutes to confirm payment of OPT fees in SEVIS.
Management of Student Data Activity
Hours Currently on OMB Inventory
New Hours
Hour Difference
Cost Currently on OMB Inventory
New Cost
Cost Difference
Off-campus and OPT employment
16,021
16,622
601
$801,686
$831,745
$30,059
STEM OPT
14,746
9,886
-4,860
$737,876
$494,689
($243,187)
OPT fee payment confirmation
0
18,850
18,850
0
$945,138
$945,138
Off-campus and OPT employment, STEM OPT, and OPT fee payment confirmation
30,767
45,357
14,590
$1,539,562
$2,271,571
$732,009
16. Published results.
DHS did not employ the use of statistics or the publication of statistics for this collection of information.
17. Waiver of display of expiration date.
SEVP will display the expiration date for OMB approval of this information collection.
18. Exception to the certification statement.
SEVP does not request an exception to the certification of this information collection.