Report: Unlawful “Public Charge” Immigration Rule Would Cost Up to $13 Billion and Separate Thousands of Families Each Year

Boundless Immigration Files Public Comment Decrying Fatally Flawed DHS “Backdoor Wealth Test”

Dec 10, 2018

Boundless vs DHS Cost Estimate

IMPORTANT UPDATE — MARCH 9, 2021: Both the new Department of Homeland Security (DHS) public charge rule and the Department of State (DOS) public charge policy are currently not in effect. The DHS rule was halted on March 9, 2021, while the DOS policy was paused indefinitely on July 29, 2020. This page reflects those policies, which initially took effect on Feb. 24, 2020, and will not be immediately updated according to the previous, longstanding guidance issued in 1999. Learn more.

SEATTLE – Boundless Immigration, a technology company empowering immigrants to more confidently and affordably navigate the U.S. immigration system, today filed an 83-page public comment opposing the “public charge” rule proposed by the U.S. Department of Homeland Security (DHS). Should the public charge rule go into effect, legal immigrants could be denied a temporary visa or a green card if they earn less than a comfortable middle-class salary, suffer from a medical condition, or have financial liabilities, among many other unprecedented disqualifying factors.

Boundless Immigration’s unique analysis demonstrates how the proposed regulation is not only bad policy, substantively unlawful, and procedurally defective, but it also betrays bedrock American principles. The full public comment can be found here:

Key findings in the Boundless public comment include:

  • The direct paperwork costs of the public charge rule could reach $13 billion each year. DHS officially predicted the annual direct costs of the public charge rule to be up to $130 million per year, but dramatically underestimated the likely size of the affected population, along with the lost wages, legal fees, and time commitment required for individuals and businesses to complete complex new filing requirements. Based on its extensive experience with immigration paperwork, Boundless re-did the DHS cost estimate with realistic assumptions, and found that the actual likely annual cost would be up to $13 billion—100 times greater than the government’s estimate.
  • The public charge rule fails at least 13 basic requirements of federal agency rulemaking. Not only is the proposed public charge rule bad policy and unlawful under the Immigration and Nationality Act, the Administrative Procedure Act, and the U.S. Constitution, but Boundless found no fewer than 13 fatal procedural defects that render the DHS proposal invalid. For example, DHS failed to quantify: (a) the direct costs of the rule as imposed by the Department of State and U.S. Customs and Border Protection; (b) the indirect costs of the rule on Americans’ public health and economic well-being; and (c) the indirect costs of impeding immigration to the United States, thereby eroding economic growth and tax revenue.
  • The public charge rule would devastate the families of U.S. citizens. By denying green cards and temporary visas to a dramatically expanded population of non-citizens who belong to American families, DHS would (a) worsen the health and well-being of U.S. citizen children; (b) prevent the families of U.S. military veterans from living together in the United States, despite DHS’s assertion that the government is “profoundly grateful for the unparalleled sacrifices of the members of our armed services and their families”; and (c) separate the spouses of nearly 200,000 U.S. citizens and lawful permanent residents each year, according to unique data analyzed by Boundless.

“As a matter of basic math, the public charge rule means massive red tape that would sink any reasonable cost-benefit analysis,” said Doug Rand, President and Co-Founder of Boundless Immigration. “As a matter of law, this policy violates a number of Congressional statutes intended to prevent executive overreach. And as a matter of principle, never in our country’s history have we required that someone be comfortably middle-class to come live and work in America.”

“Thank goodness we didn’t have this policy in place when future business icons like Andrew Carnegie and Sergey Brin came to this country with nothing,” added Xiao Wang, CEO and Co-Founder of Boundless, who came to America himself at age 3 after China’s Cultural Revolution. “This backdoor wealth test goes against what makes America great.”

Rand and Wang are available for interviews. To arrange an interview, please contact


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 has helped thousands of people with their green card and U.S. citizenship applications each month. Co-founded by CEO Xiao Wang, President Doug Rand, and CTO Serdar Sutay, Boundless dramatically streamlines 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.