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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Published Nov 10, 2026 NASHVILLE, Tenn. — Today, a judge signed an order extending a temporary restraining order (TRO) requiring the Tennessee Department of Safety and Homeland Security (TDOS) to continue issuing temporary driver's licenses to non-U.S. citizens...
TIRRC v. Tennessee Department of Safety and Homeland Security, Jeff Long
This case challenges a new rule from the Tennessee Department of Safety and Homeland Security (TDOS) that blocks many non-U.S. citizens from getting temporary driver’s licenses, even when they have authorization from the federal government to...
Last update: Nov 10, 2026