EOIR-31A Narrative of Changes 2019

EOIR-31A
INSTRUCTIONS
The new Purpose of Form provides more substantive information on what initial
accreditation is, including examples of when organizations need to submit separate
applications for the same individual. This section also gives more detail on renewal of
recognition and addresses change of accreditation type.
We moved the Program’s mailing address to the end of the form.
The How to Complete section provides a lot more detail about the regulatory
requirements, aimed at assisting the organization submit a complete package from the
beginning and preventing multiple communications to the organization to submit
supplemental documentation.
Part 1.
The old Part 1 focused on the organization seeking accreditation of a representative.
The new Part 1 focuses on the individual for whom the organization is seeking
accreditation. Consequently, the new form no longer collects:
Other names the organization used
Names the organization previously applied under
Address, telephone, fax, and email of the organization
Date of organization’s last approval of recognition
However, the new forms does collect:
Daytime phone number and email of individual
Whether the renewal application is for partial or full accreditation
Whether the change of accreditation type is partial to full or full to partial
Address(es) where proposed representative works or intends to work
Part 2.
The information in old Part 2 is now collected in either new Part 1 or new Part 2A.
The new Part 2A specifically asks if the individual is an attorney, and whether the
individual’s status with the organization is employee, volunteer, or other.
The new Part 2A also asks for the name of the organization that has ever submitted an
application on behalf of the individual, what the outcome was of the application, and
the reasons for the individual leaving that organization (if applicable).
The new Part 2B and 2C address many of the topics from old Part 4.
The new Part 2B specifically asks if the representative possesses broad knowledge and
adequate experience in immigration law and procedure.

The new Part 2B also lists one by one the specific documents required to demonstrate
knowledge and experience rather than referring to the requirements more broadly with
a reference to the form instructions as in old Part 4.
For renewal applications, the new Part 2B asks how frequently the representative has
provided direct legal representation before USCIS or EOIR within the past three years
or since last accredited.
The new Part 2C asks for the individual’s date of birth. This information is important if
EOIR Fraud wants to conduct a background check or ask USCIS FDNS to conduct a
criminal background check on the proposed representative.
The new Part 2C sets up a series of yes/no questions that follow the requirements of
8 CFR § 1292.12. This Part specifically asks if the representative has ever practiced law
without authorization, and if the representative ever committed a crime of any kind.
These questions are important to help us identify individuals who may be involved in
the unlawful practice of law or do not have the required character and fitness to
represent clients.
Part 3.
We incorporated Part 3 into new Part 1.
Part 4.
We incorporated old Part 4 into new Parts 2A, B, C.
Part 5.
We incorporated old Part 5 into Parts 1 and 2.
Part 6.
The declarations under old Part 6 have been reformatted and appear separately in new
Parts 3 and 4. The new Part 3 provides a space for the Authorized Officer to write in the
name of its organization. The new information collected in new Part 4 is the date the
representative signs the form.
Part 7.
The old Part 7 appears as new Part 5, providing a line to list the name of the USCIS
District Office and allowing entry for the mailing address of only one District Office.