Ms. Samantha Deshommes, Chief Regulatory Coordination Division
Office of Policy and Strategy
U.S. Citizenship and Immigration Services
Department of Homeland Security
20 Massachusetts Ave. NW
Washington, DC 20529
Re: U.S. Citizenship and Immigration Services Fee Schedule, DHS Docket No. USCIS-2019-0010; RIN 1615-AC18
Dear Chief Deshommes,
Please find attached the comments of the Hope Enterprise Corporation / Hope Federal Credit Union (HOPE) in response to the proposed changes to the U.S. Citizenship and Immigration Services Fee Schedule. HOPE is a National Credit Union Administration Low-Income designated credit union and a U.S. Treasury certified Community Development Financial Institution with a mission of strengthening communities, building assets, and improving lives in economically distressed areas throughout Alabama, Arkansas, Louisiana, Mississippi and Tennessee.
Over half of HOPE’s members earn incomes below $35,000. The significant majority of HOPE’s members are Black and/or Latino. Throughout the Deep South, many of the residents served by HOPE are immigrants.
We are concerned that the proposed fee increases for naturalization and Deferred Action for Childhood Arrivals (DACA) will deepen the financial burden for our members and their families seeking educational opportunities for economic advancement and citizenship.
Specifically, feedback from multiple members confirm the proposed fee increases are not affordable for individuals struggling to make ends meet.
Additionally, the proposed fee increases, combined with the cost of legal representation, will delay filing for citizenship and the attainment of post-secondary credentials.
The proposed fee increases disproportionately affect low-income immigrants and force difficult choices between covering basic living costs and the attainment of documents needed for work, school and accessing basic services. Additionally, as we have seen with other members who are not immigrants, when faced with financial difficulties, low-income members fall prey to predatory lending and high cost financial services.
Once caught in the debt trap of predatory loans, the financial challenges associated with immigration and daily living expenses are exacerbated.
For these reasons, we oppose the fee increases referenced in this comment letter and urge the Department of Homeland Security to reconsider the proposed changes.
Thank you for the opportunity to share our perspective on the proposed rule changes. If you have any questions, please feel free to contact me at Bill.Bynum@hope-ec.org.
Sincerely,
