Dear Division Chief Mark Phillips:
The National Immigration Law Center (NILC) welcomes the opportunity to respond to the Interim Final Rule (IFR) on “Alien Registration Form and Evidence of Registration” published on March 12, 2025, which completely fails to acknowledge the sweeping administrative, fiscal, and human costs posed by its implementation. This comment also responds to the information collection effectuated through Form G-325R – Biographic Information (Registration), OMB Control Number 1615-NEW. We urge the Department of Homeland Security (DHS) and its component U.S. Citizenship and Immigration Services (USCIS) (hereinafter “the Department” or “DHS”) to immediately rescind the IFR and eliminate this unnecessary, highly costly, and irreparably harmful process. The only appropriate rulemaking on registration is the removal of 8 C.F.R. Part 264 in its entirety in light of the obsolescence of the underlying legal regime.
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