60 Day Public Comment Response Matrix

I-914-012_60 Day Public Comment Response Matrix.pdf

Application for T Nonimmigrant Status; Application for Immediate Family Member of T-1 Recipient; & Declaration of Law Enforcement Officer for Victim of Trafficking in Persons

60 Day Public Comment Response Matrix

OMB: 1615-0099

Document [pdf]
Download: pdf | pdf
Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
Comment #/Topic
1.

2.
Form I-914

Commenter ID
USCIS-20060059-0118

USCIS-20060059-0119

Comment
Commenter: jean publieee
no foreigner shoudl come to this
country and be let to just walk right
in as the demented bidenis doing
these days in direct opposotion
althought he is aware that 76% of the
citizens of this country dont want this
to go on. he cannot continue on this
unauthroized since we are to have a
govbt of the people by teh people.
open and ttansparent. but he is
sneaky as can be and lies tot he
american people and works against
them consjtantly. so many of his
actions are anti american like
bringing in allt hese foreigmnmers
with their criminality, their failure to
live up to american laws . theyviolate
our laws constantly. they need to all
be sentback to their owncouhntry.
we will have alot of repair work to do
when biden leaves office. he is ruiing
this country. i am totally opposed to
this inclusion of t non im.migrants.
we need to close our borders. biden
has invited in criminals, ruffians, law
breakers, liars.
Commenter: Carson Osberg
See attachment at USCIS-2006-00590119

Page 1 of 13

USCIS Response
Response: This comment is
out of scope for the
intended information
collection because it does
not provide feedback on the
nature of the information
collection, the categories of
respondents, the estimated
burden (i.e. the time, effort,
and resources used by the
respondents to respond),
the estimated cost to the
respondent, or the actual
information collection
instrument.

Response: See Comment
Responses below labeled
with Commenter ID: USCIS2006-0059-0119. The
commenter provided
bulleted suggestions in a
letter which GSA posted to
the docket as an
attachment. The attachment
is available at this link
USCIS-2006-0059-0119.
Each bulleted suggestion
has been separated into
different sections in this
comment matrix to address
each portion of information
individually.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
See Comments 3 - 42.

3.
Form I-914

4.
Form I-914

5.
Form I-914

6.
Form I-914

7.
Form I-914

8.
Form I-914

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

Commenter: Carson Osberg
Page 1, Part 1, Question 1: I suggest
making the radio buttons either/or
options, as an applicant has either
never filed for T-1 status previously,
or they have. Both (A) and (B) cannot
both be simultaneously true.
Commenter: Carson Osberg
Page 1, Part 2, Question 3 (Physical
Address): I suggest a note here or in
the instructions that the applicant’s
complete address does not need to
be included, for safety and
confidentiality reasons, but that the
city and state or zip code are
required for biometrics scheduling
purposes.
Commenter: Carson Osberg
Page 1, Part 2, Question 4 (Safe
Mailing Address): If “Apt.,” “Ste.,” or
“Flr.” is selected, the same is
automatically selected for the Law
Enforcement Agency on Page 3, Part
3, Question 5.
Commenter: Carson Osberg
Page 1, Attorney State License Bar
Number: I suggest correcting this
field as it does not currently allow
numbers.
Commenter: Carson Osberg
Page 2, Part 2, Question 8 (Gender):
In order to be more inclusive and
representative, I suggest updating
these options to include a non-binary
or other option. The I-914A currently
includes “other” as an option.
Commenter: Carson Osberg
Page 2, Part 3, Questions 2 & 7: I
suggest revising as both of these
questions address cooperating with
Page 2 of 13

Response: USCIS will review
the form field functionality
for this question.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS will review
the form field functionality
for this question.

Response: USCIS will review
the form field functionality
for this question.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
reasonable requests from law
enforcement and are therefore
partially duplicative.
9.
Form I-914

10.
Form I-914

11.

USCIS-20060059-0119

USCIS-20060059-0119

Commenter: Carson Osberg
Page 4, Part 4: I recommend
including a note stating that vacated
crimes meeting the Pickering
standard—which were vacated due
to a substantive, statutory, or
procedural defect--do not need to be
listed on Form I-914. Many trafficking
survivors are forced or coerced into
committing crimes as part of their
victimization, and state legislatures
are increasingly acknowledging
forced criminality by enacting vacatur
legislation to allow the vacatur of
criminal acts for trafficking victims,
voiding the earlier judgment. In
recognition of the legal error, vacatur
also leads to the destruction of the
related criminal records. For instance,
in California, under Cal. Penal Code §
236.14(k), government agencies are
required to seal and destroy such
records and there is often no
recourse to obtain a copy from the
court. Therefore, I suggest that USCIS
indicate in this explanation that if a
crime has been vacated, additional
documentation is unnecessary, and
the crime does not need to be listed
on Form I-914.
Commenter: Carson Osberg
Page 5, Part 4, Question 3D & 4B4: I
suggest revising to “one or more
individuals.”

Commenter: Carson Osberg

Page 3 of 13

consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
Form I-914

12.
Form I-914A

13.
Form I-914A

14.
Form I-914A

15.
Form I-914A

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

Page 9, Part 7, Interpreter’s Contact
Information: I suggest including a
note indicating where applicants can
provide information about additional
interpreters used. In cases involving
rarer languages, multiple interpreters
may be required, such as for
interpretation from English to
Spanish to an indigenous language,
and vice versa. I recommend either
allocating space for an additional
interpreter or providing guidance on
what to include in the "Additional
Information" section.
Commenter: Carson Osberg
Page 1, Part 3, #3: When completing
the T-1’s A# here, the derivative A#
field on page 2 auto-populates. I
suggest correcting this form error.
Commenter: Carson Osberg
Page 2, Part 4, #3 (U.S. Physical
Address or Intended Physical
Address): I suggest noting here that
the derivative applicant’s full
intended U.S. address does not need
to be included for safety and
confidentiality reasons.
Commenter: Carson Osberg
Page 9, Part 7, Interpreter’s Contact
Information: I suggest including a
note indicating where applicants can
provide information about additional
interpreters. In cases involving rarer
languages, multiple interpreters may
be required, such as for
interpretation from English to
Spanish to an indigenous language,
and vice versa. I recommend either
allocating space for an additional
interpreter or providing guidance on
what to include in the "Additional
Information" section.
Commenter: Carson Osberg
Pages 9-10, Part 7, Interpreter’s
Contact Information: I suggest
Page 4 of 13

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS will review
the form field functionality
for this question.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

16.
Form I-914A

17.
Form I-914A

18.
I-914 & I-914A
Instructions

19.
I-914 & I-914A
Instructions

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

including a note indicating where
applicants can provide information
about additional interpreters. In
cases involving rarer languages,
multiple interpreters may be
required, such as for interpretation
from English to Spanish to an
indigenous language, and vice versa. I
recommend either allocating space
for an additional interpreter or
providing guidance on what to
include in the "Additional
Information" section.
Commenter: Carson Osberg
Page 11, Part 8 (Preparer’s Mailing
Address), #3: The field allows no
space between the street number
and street name. I suggest correcting
this form error.
Commenter: Carson Osberg
Page 12, Part 9 (Additional
Information): The T-1’s name and A#
automatically populate here, though
the form primarily collects
information about the derivative
beneficiary. I suggest correcting this.
Commenter: Carson Osberg
General: I suggest referencing the
USCIS Policy Manual for pro se
individuals who are unlikely to be
aware of existing guidance regarding
T nonimmigrant status. Also suggest
providing a link to OVC-funded legal
service providers so that
unrepresented individuals may
attempt to seek free or low-cost
representation, which is more
efficient and effective for both
applicants and USCIS.

Commenter: Carson Osberg
Page 1, #1(C): I suggest clarifying that
the age-based exemption applies to
Page 5 of 13

suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS will review
the form field functionality
for this question.

Response: USCIS will review
the form field functionality
for this question.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

20.
I-914 & I-914A
Instructions

USCIS-20060059-0119

21.
I-914 & I-914A
Instructions

USCIS-20060059-0119

22.
I-914 & I-914A
Instructions

USCIS-20060059-0119

23.
I-914 & I-914A
Instructions

USCIS-20060059-0119

24.

individuals who were under 18 at the
time of the trafficking victimization,
not at the time of filing Form I-914.
(This should also be clarified on page
14.) 3 USCIS-PM B.2.D.5.
Commenter: Carson Osberg
Page 1, #2: I suggest clarifying that no
I-914A may be filed once the T-1 no
longer holds T nonimmigrant status
(e.g. it expires or they have adjusted
status).
Commenter: Carson Osberg
Page 1, #2: I suggest clarifying that
age-out protections exist beyond the
date of adjudication of the T-1
application, as per the T visa
regulations, as this question comes
up fairly regularly. For example, if an
I-914A is filed after the T-1 has
turned 21 and after the I-914 has
been granted, the derivative
beneficiary still retains eligibility.
(This should also be clarified on page
9.)
Commenter: Carson Osberg
Page 2, Completing form I-914, Part
1. Purpose for Filing This Application:
I suggest revising the following, as I
am not clear on its purpose here,
since all derivatives must be applied
for using Form I-914A: “If you are
only filing for a T-6 derivative, you
should leave Part A. blank.”
Commenter: Carson Osberg
Page 2, Part 2. General Information
About You, #3: I suggest noting here
that the applicant’s complete address
does not need to be included, for
safety and confidentiality reasons,
but that the city and state or zip code
are required for biometrics
scheduling purposes.
Commenter: Carson Osberg
Page 6 of 13

suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
I-914 & I-914A
Instructions

USCIS-20060059-0119

25.
I-914 & I-914A
Instructions

USCIS-20060059-0119

Page 4, Completing Form I-914,
Supplement A, Application for Family
Member of T-1 Recipient:
o I suggest clarifying that no I914A may be filed once the T1 has adjusted to permanent
residence, no I-914A may be
filed and no I-914A
beneficiary may be admitted
into the U.S. in T
nonimmigrant status, as this
is critical information for a T1 to be aware of.
o I suggest revising this
language (“must be
accompanied by a copy of
the principal applicant’s Form
I-914”) to state that any I914A filed after the principal
applicant’s I-914 should be
filed with a copy of the
principal applicant’s T-1
receipt or approval notice. In
practice, a full copy of Form I914 has not been required,
and I am concerned that
including such a copy could
cause confusion by mailroom
employees. (This
requirement is also
mentioned on page 7 of the 4
instructions.) Including a
copy of the T-1 receipt or
approval notice seems much
more relevant in this context
than a copy of a form that
may or may not have been
properly receipted by USCIS,
and that may have already
been denied.
Commenter: Carson Osberg
Page 5, Part 4, Q14: I suggest revising
as follows: “Provide your relative’s
current status, regardless of how you
they entered…”
Page 7 of 13

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

26.
I-914 & I-914A
Instructions

USCIS-20060059-0119

27.
I-914 & I-914A
Instructions

USCIS-20060059-0119

28.
I-914 & I-914A
Instructions

USCIS-20060059-0119

29.

Commenter: Carson Osberg
Page 4, Part 7 (Interpreter’s Contact
Information, Certification, and
Signature): I suggest clarifying that no
signature is required where phone
interpretation is used and instead,
the interpreter identification number
and name of the interpretation
company should be included, where
applicable.
Commenter: Carson Osberg
Page 8, Evidence to Establish T
Nonimmigrant Status: I suggest
clarifying the language here, as the
age-based cooperation exemption
applies at the time of trafficking
victimization, not the time of filing.
Suggested new language: “…unless
you were under the age of 18 during
any part of your trafficking.” 3 USCISPM B.2.D.5.
Commenter: Carson Osberg
Page 9, Evidence to Establish
Derivative T Nonimmigrant Status: I
suggest correcting the following
sentence as follows: “If you are under
21 years of age at the time you file
your application, USCIS will continue
to consider your parent or unmarried
sibling to have the required qualifying
relationship.” As written, the current
sentence is unclear as to what
“consider” means. Also suggest
clarifying that age-out protections
exist beyond the date of adjudication
of the T-1 application, as per the T
visa regulations. For example, if an I914A is filed after the T-1 has turned
21 and after the I-914 has been
granted, the derivative beneficiary
still retains eligibility.
Commenter: Carson Osberg
Page 8 of 13

recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023
I-914 & I-914A
Instructions

30.
Form I-914B

31.
Form I-914B

32.
Form I-914B

33.
Form I-914B

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

Page 12, Processing Information: As
written, it appears that both T-1
nonimmigrants and T derivatives are
authorized to work incident to status.
“If your application is approved, you
will be authorized to work.” Suggest
revising that initial sentence and
clarifying that only T-1
nonimmigrants are authorized to
work incident to status and need not
present an Employment
Authorization Document, while T
derivatives must obtain an EAD. 8
CFR §§ 274a.12(a)(16), (c)(25).
Commenter: Carson Osberg
Page 1, Part 2 (Agency Information):
The Apt., Ste., or Flr. number field
does not accept a response. I suggest
correcting this form error.
Commenter: Carson Osberg
Page 2, Part 3, Question 3: I suggest
revising the following to: “Has the
applicant expressed any fear of
retaliation or revenge if they had to
depart from or were removed from
the United States?” Many survivors
do not specifically express fears
relating to removal, but rather,
express fear of return or harm in
home country generally.
Commenter: Carson Osberg
Page 3, Part 3, Question 4: Often, the
dates of the criminal activity are a
range rather than specific dates. I
suggest revising this section so
specific dates or a range of dates can
be included.
Commenter: Carson Osberg
Page 3, Part 3, Question 6: I suggest
the following: “Provide the date on
which the investigation or
prosecution was initiated, if
applicable.” Sometimes an LEA will
Page 9 of 13

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS will review
the form field functionality
for this question.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

34.
Form I-914B

35.
Form I-914B

36.
Form I-914B

37.
Form I-914B

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

USCIS-20060059-0119

sign an I-914B even where a formal
investigation has not been opened.
Commenter: Carson Osberg
Page 3, Part 3, Question 7: I suggest
the following: “Provide the date on
which the investigation or
prosecution was completed, if
applicable.” An LEA may sign this
form prior to the conclusion of the
investigation or prosecution.
Commenter: Carson Osberg
Page 3, Part 4, Question 1D: I suggest
revising this because the age of
majority is relevant to when the
trafficking took place, not the age at
the time of LE involvement. 3 USCISPM B.2.D.5. I suggest the following
language here: “Was under the age
of 18 at the time of the trafficking
victimization.”
Commenter: Carson Osberg
Page 3, Part 5, Question 1: I suggest
revising to “Are any of the applicant’s
family members believed to have
been involved in his or her the
applicant’s trafficking to the United
States?” The current language is
misleading because there is no
requirement that an individual be
trafficked to the U.S.; they could
already be within the U.S. and
trafficked once here, and a family
member could be complicit in that
trafficking in either scenario. Given
that law enforcement is sometimes
unfamiliar with trafficking or newer
to the nuances of trafficking, I
suggest making sure the language in
this form and any guidance is clear.
Commenter: Carson Osberg
Page 4, Part 6, Question 2:
o There is not always both a
law enforcement officer and
a supervisor of the certifying
officer available to sign this
Page 10 of 13

the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

o

form. For example, a unit
chief could be both the
investigating officer and the
certifying official, or a judge
may sign the form as the
certifying official with the
ability to detect trafficking. I
suggest clarifying in the form
and instructions how to
handle in these situations to
reduce barriers and
encourage the form’s use.
Additionally, the form
language is not entirely
consistent with the T Visa
Law Enforcement Resource
Guide, which could cause
confusion and, therefore,
reluctance to complete a
Form I-914B. On page 4,
Form I-914B seeks the
signature of the “Law
Enforcement Officer,” who is
referred to in Part 2 (page 1)
as the “certifying official,”
and the “Supervisor of
Certifying Officer.” The T Visa
Law Enforcement Resource
Guide states the following,
which makes it seem like the
supervisor is the one with
certifying authority (in
contrast to the form
language): “Officials With
Signing Authority: The
supervising official
responsible for the detection,
investigation, or prosecution
of severe forms of trafficking
in persons at your law
enforcement agency must
sign Form I-914B. You are the
supervising official of your
agency if you are in a
supervisory role and your
agency has designated you a

Page 11 of 13

the next revision action to
Form I-914.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

38.
I-914B
Instructions

USCIS-20060059-0119

39.
I-914B
Instructions

USCIS-20060059-0119

“supervising official.” There is
also an area designated on
the declaration for the
signature of a law
enforcement officer who is
directly familiar with the
case.” I would recommend
clarification of the form
language and accompanying
instructions and/or the T Visa
Law Enforcement Resource
Guide so the information on
who must sign and their
respective role is clear in
both places.
Commenter: Carson Osberg
Page 1, What is the Purpose of Form
I-914 Supplement B?: I suggest citing,
as early as possible in the
instructions, to the regulations or
policy manual language that provides
examples of who can sign an I-914B,
as well as to DHS’s T Visa Law
Enforcement Resource Guide, so that
potential certifiers do not have to go
digging to ascertain if they are able to
sign an I-914B.
Commenter: Carson Osberg
Page 1, When Should I Use Form I914, Supplement B?: I suggest
revising the existing language as
follows: “You do not need to
formally launch an investigation or
file charges to complete Form I-914,
Supplement B. You may complete
Supplement B if an investigation
does not lead to an arrest or a
prosecution. Additionally, you may
complete Supplement B even if a
victim decides to stop cooperating in
an investigation or prosecution
because they fall under the agebased exemption or trauma-based
exception at 8 CFR § 214.11(b)(3).
Completing Supplement B is not
contingent on the outcome of a
Page 12 of 13

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.

Form I-914-012 Revision Responses to 60-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2006-0059
60-day FRN Citation (federalregister.gov): 88 FR 48488
Publish Dates: July 27, 2023 – Sept 25, 2023

40.
I-914B
Instructions

USCIS-20060059-0119

41.
I-914B
Instructions

USCIS-20060059-0119

42.
I-914B
Instructions

USCIS-20060059-0119

prosecution or investigation.
Completing Supplement B is at your
discretion. There is no statute of
limitations related to completing
Supplement B.”
Commenter: Carson Osberg
Page 3, Part 3, 1B: I suggest clarifying
the following language: “Sex
trafficking where the victim is was
under 18 years of age at the time of
the trafficking criminal activity.” (This
should also be corrected on Page 3,
Part 4.)
Commenter: Carson Osberg
Page 3, Part 6, Attestation: I suggest
clarifying that in some instances, the
investigating officer and the
certifying supervisor may be the
same individual.
Commenter: Carson Osberg
Finally, when a new form version is
issued, I would strongly urge a
minimum of at least 60 days’ notice
that the edition date is changing and
ideally 180 days, as the agency has
provided in the past when the I-918
and related forms were expiring, to
avoid submission of outdated forms
and additional burden on applicants,
certifying agencies, legal
representatives, and USCIS.

Page 13 of 13

Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.
Response: USCIS is not
adopting the commenter’s
suggestions, but may
consider these
recommendations during
the next revision action to
Form I-914.


File Typeapplication/pdf
AuthorStout, Samantha J
File Modified2023-10-30
File Created2023-10-11

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