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Without Congress, DHS Plans New Obstacles for Immigrants Seeking U.S. Citizenship

Jan 28, 2019

SEATTLE — Boundless Immigration, a technology company empowering immigrants to more confidently and affordably navigate the U.S. immigration system, filed a 20-page public comment opposing new obstacles for immigrants seeking U.S. citizenship. The changes — a set of updates to the Application for Naturalization (Form N-400) — were proposed by the Department of Homeland Security (DHS) and very quietly set in motion this past week.

Should the changes go into effect, the citizenship application form will then require (a) up to 10 years of travel history rather than the status quo of five years; (b) much more complicated documentation up front, such as tax returns and children’s birth certificates; and (c) much more expansive and ambiguous questions about an applicant’s “good moral character,” which includes such qualities as having no criminal history and meeting one’s tax obligations.

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Boundless Immigration’s detailed analysis demonstrates how these citizenship-application changes would be substantively unlawful, procedurally flawed, and needlessly costly for immigrants seeking U.S. citizenship. The full public comment is available here.

Key findings in the Boundless public comment include the following:

  • These changes to the citizenship application are unlawful. DHS is seeking to cloak major policy changes under the guise of updating a government form, which violates the Immigration and Nationality Act, the Administrative Procedure Act, and the agency’s own regulations. In addition, Boundless found numerous violations of the Paperwork Reduction Act, which is supposed to ensure that changes to government forms reduce complexity and public burden.
  • Immigrants would be ensnared by unnecessary and confusing new requirements. It’s hard enough for immigrants seeking citizenship to track down the details of every international trip longer than 24 hours from the past five years — now DHS plans to double that period to up to 10 years, even though trips taken that long ago have no bearing on eligibility for U.S. citizenship. Moreover, DHS seeks to ask immigrants a raft of new questions that are so broad and ambiguous they will inevitably create confusion. One such question is, “Have you belonged to any group that used weapons or engaged in violence?” Would these groups include, for instance, martial-arts programs or hunting and rifle clubs?
  • The extra paperwork costs for immigrants would exceed $150 million each year. DHS underestimated the extra red-tape burden on citizenship applicants by over 600 percent, by mischaracterizing the lost wages and time commitment required for immigrants to complete these complex new filing requirements.

“These proposed changes are fundamentally aimed at discouraging legal permanent residents from achieving their dream of becoming U.S. citizens,” said Xiao Wang, CEO of Boundless. “Adding unnecessary complexity to the citizenship application would only increase government inefficiency, which runs counter to U.S. law, does nothing to improve our national security, and alienates immigrants seeking to better their lives and contribute to this country.”

Wang is available for interviews. To arrange an interview, please send an email to [email protected].


Boundless Immigration ( is dedicated to empowering families to navigate the immigration system more confidently, rapidly, and affordably. Established in 2017 by immigration and technology experts — many of whom went through the U.S. immigration process themselves — the company helps thousands of people with their green card and U.S. citizenship applications each month. Boundless has dramatically streamlined these immigration processes by integrating technology with a network of independent immigration attorneys, at a fraction of the cost of a traditional attorney.

Boundless — for people who want the expertise
of an immigration lawyer, not the price tag.