Comments of Boundless Immigration Inc. on the Department of Homeland Security’s Proposed Rules - USCIS Fee Schedule and Changes to Certain Other Immigration Benefit Request Requirements

Sep 19, 2026

Boundless Immigration Inc. submits detailed comments on the Department of Homeland Security’s proposed rules affecting the U.S. Citizenship and Immigration Services fee schedule and certain immigration benefit request requirements. The filing argues the proposal would create severe and irreparable harms across multiple groups, including immigrants eligible for citizenship, lawful permanent residents, married couples, re-entry seekers, green card applicants and families, asylees, DACA beneficiaries, and victims of domestic violence or trafficking. It further contends the rule is unlawful under statutory, congressional intent, Administrative Procedure Act, and reliance-interest grounds, citing multiple specific areas of legal deficiency.

LanguageEnglish

CategoryLetters

FormatPDF

Pages65

Reading Time23 min

AccessFree to download

Background

The Proposed Rule Would Impose Severe and Irreparable Harms

Harms to immigrants eligible for U.S. citizenship

Harms to lawful permanent residents

Harms to married couples

Harms to individuals seeking lawful re-entry to the United States

Harms to green card applicants and their U.S. family members

Harms to asylees

Harms to DACA beneficiaries

Harms to victims of domestic violence and human trafficking

Harms to family members of crime victims

Harms to families who fled Central America and the Soviet Union

Harms to family history researchers

Harms to U.S. citizens

Harms to U.S. small businesses

Harms to all U.S. businesses

Harms to all underbanked users

Harms to all users of the legal immigration system

Harms to all citizens and residents of the United States

The Proposed Rule Is Unlawful

The proposed rule is contrary to Congressional intent

The proposed rule violates a plain reading of the Immigration and Nationality Act

The proposed rule violates the will of Congress as expressed through bipartisan appropriations language

The proposed rule violates the Immigration and Nationality Act, the Homeland Security Act, and two Appropriations Acts in proposing a user fee transfer to ICE

The proposed rule’s arbitrary and pretextual “equity” principle is contrary to the Administrative Procedure Act

It is arbitrary to eliminate fee caps for some but not all categories

It is arbitrary to eliminate and restrict fee waivers without a rational policy argument

The proposed rule is inconsistent with prior practice

The proposed rule violates reliance interests

The proposed rule ignores Congressional intent

It is arbitrary to eliminate free interim benefits without a rational policy argument

It is arbitrary to impose an essentially random fee on asylum applicants

It is arbitrary to impose an extraordinary new work permit fee on asylum applicants

It is arbitrary to impose an essentially random fee on TPS

It is arbitrary to reverse longstanding naturalization policy

The proposed rule’s cost/benefit analysis is utterly deficient and violates the Administrative Procedure Act

The economic analysis is mathematically invalid

There is no accounting for harms

Comments of Boundless Immigration Inc. on the Department of Homeland Security’s Proposed Rules: U.S. Citizenship and Immigration Services Fee Schedule and Changes to Certain Other Immigration Benefit Request Requirements 84 Fed. Reg. 62280 (Nov. 14, 2019) and 84 Fed. Reg. 67243 (Dec. 9, 2019) Doug Rand Co-Founder Boundless Immigration Inc. 101 4th Ave, Suite 850 Seattle, WA 98121 December 30, 2019 Table of Contents Background .................................................................................................................................... 4 The Proposed Rule Would Impose Severe and Irreparable Harms............................................. 4 Harms to immigrants eligible for U.S. citizenship............................................................................... 6 Harms to lawful permanent residents................................................................................................... 7 Harms to married couples ..................................................................................................................... 8 Harms to individuals seeking lawful re-entry to the United States.................................................... 8 Harms to green card applicants [and their U.S. family](and their U.S. family) members ....................................................... 8 Harms to asylees ..................................................................................................................................... 9 Harms to DACA beneficiaries ............................................................................................................... 9 Harms to victims of domestic violence and human trafficking ........................................................ 10 Harms to family members of crime victims ....................................................................................... 10 Harms to families who fled Central America and the Soviet Union ................................................ 10 Harms to family history researchers................................................................................................... 11 Harms to U.S. citizens .......................................................................................................................... 11 Harms to U.S. small businesses ........................................................................................................... 12 Harms to all U.S. businesses ................................................................................................................ 12 Harms to all underbanked users ......................................................................................................... 12 Harms to all users of the legal immigration system........................................................................... 13 Harms to all citizens and residents of the United States ................................................................... 13 The Proposed Rule Is Unlawful .................................................................................................. 14 The proposed rule is contrary to Congressional intent ..................................................................... 14 The proposed rule violates a plain reading of the Immigration and Nationality Act ......................................... 14 The proposed rule violates the will of Congress as expressed through bipartisan appropriations language ...... 14 The proposed rule violates the Immigration and Nationality Act, the Homeland Security Act, and two Appropriations Acts in proposing a user fee transfer to ICE ............................................................................. 17 The proposed rule’s arbitrary and pretextual “equity” principle is contrary to the Administrative Procedure Act................................................................................................

FAQs

What rule changes does Boundless Immigration Inc. comment on?

Boundless Immigration Inc. comments on the Department of Homeland Security’s proposed USCIS fee schedule and changes to certain other immigration benefit request requirements, addressing how fees and related policies would affect applicants and other stakeholders.

Which groups does the filing say would face severe harms?

The filing alleges harms would fall on immigrants eligible for U.S. citizenship, lawful permanent residents, married couples, individuals seeking lawful re-entry, green card applicants and their U.S. family members, as well as asylees, DACA beneficiaries, and victims of domestic violence or human trafficking, among others.

On what legal grounds does the filing argue the proposed rule is unlawful?

The filing argues the proposal is contrary to congressional intent and violates the Immigration and Nationality Act and related statutory schemes. It also claims inconsistency with prior practice, violation of reliance interests, and an inadequate cost/benefit analysis under the Administrative Procedure Act.

Sep 19, 2026

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