On December 31, 2015 issued a long awaited proposed regulation that was supposed to change the lives of tens of thousands of immigrants stuck in long visa queues by providing work cards to allow them the freedom to change employers and get on with their lives. It was also supposed to make it possible for people waiting on an immigrant visa queue to be able to leave an employer and not lose their priority date. And it was supposed to bring long awaited structure to the AC21 legislation.
Unfortunately, the regulation fails to deliver on many fronts. Perhaps the biggest disappointment concerned the section providing employment cards for people in long green card queues. USCIS had the opportunity to make a genuine impact for good and instead issued a rule that is, to be frank, insulting to that community of contributors to American society.
Here is my detailed comment on why I think this rule is a failure.
[Update: Some people were wondering if these comments were just written for the blog or were submitted to the government. They were submitted last night and the Comment Tracking Number is 1k0-8o84-c7x5].
comments on AC21 and I-140 regs