Posted on: September 19th, 2011
by Greg Siskind
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USCIS has been using the VIBE system (Validation Instrument for Business Enterprises) pilot program in most I-129 filings, including H-1B petitions. VIBE is of course a new method for USCIS officers to verify petitioner information in adjudicating employment-based petitions. The program gives immigration officers access to information about the petitioning company from Dunn & Bradstreet (“D&B”), which is a private company which specializes in providing credit reporting and other information about companies. Obviously many companies, especially small and midsize companies are concerned that there may be inaccurate information in D&B, which has caused USCIS to issue onerous requests for evidences (RFEs) to small companies.
Most companies have no reason to update their D&B information, especially if they do not borrow money from banks or apply for credit lines at banks or with vendors.
In some cases, especially when we had repeat VIBE RFEs for companies, we suggested to our clients to update their D&B information before filing H-1B petitions with USCIS. This is fine, but the company has to first obtain a D-U-N-S number from D&B, which either takes 30 days to obtain or can be done faster for another payment of $299 to D&B.
VSC has indicated last week that its database is updated when contradictory information gets resolved between the information in D&B/VIBE and the information a petitioner provides.
VSC has also said that VIBE RFEs indicate that petitioners may wish to update their information in the D&B database. Given that D&B is a commercial database, there is a very real concern that information offered by petitioners to D&B may be sold or otherwise misused by D&B for commercial gain. VSC also cannot guarantee the privacy of that information. Therefore, VSC recommended that petitioners be careful in deciding whether to update their information in the D&B database given that it is not mandatory. The D&B database also offers an expedited process for updating the database by paying an extra fee. However VSC said that it does not lead to the USCIS databases being updated any quicker, so VSC acknowledged that the D&B expedite fee is not warranted.