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April 5, 2019
Boundless Immigration, a technology company empowering immigrants to more confidently and affordably navigate the U.S. immigration system, filed a 19-page public comment opposing new obstacles for U.S. citizenship applicants. The changes — a set of updates to the Notice of Naturalization Oath Ceremony (Form N-445) — were proposed by the Department of Homeland Security (DHS) and set in motion on February 1. The public comment period closed on April 2.
Boundless Immigration opposes the changes on the grounds they are unlawful, unnecessary, confusing, and expensive. “These proposed changes to Form N-445 by no means enhance the naturalization process — for either citizenship applicants or DHS staff who must collect the information,” said Xiao Wang, CEO of Boundless Immigration. “At worst, the changes serve only to intimidate and alienate new Americans at the very moment our nation is poised to embrace them as full citizens.”
The longstanding purpose of Form N-445 is simply to confirm that an applicant for U.S. citizenship remains eligible during the months between their successful naturalization interview and their final Oath of Allegiance ceremony. But DHS plans to complicate this form by requiring extensive additional documentation, adding a translator certification requirement, and asking a tortuous question about criminal activity, among other changes.
Boundless Immigration’s detailed analysis — demonstrating how these Form N-445 changes would be substantively unlawful and needlessly burdensome for immigrants on the home stretch for U.S. citizenship — is available here.
Key findings in the Boundless public comment include the following:
Wang added: “Of the nearly 9 million green card holders eligible for U.S. citizenship today, fewer than 1 million will actually apply in any given year because of barriers like the changes DHS has proposed. Putting additional barriers so close to the finish line of a journey that has lasted many, many years is counter to supporting legal immigration.”
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