CDMA Comments on Provisional Unlawful Presence Waivers Proposed Rule

"[C]ertain aspects of the way in which USCIS proposes to implement this technical fix in the proposed rule will unnecessarily limit its positive effects and lead to an unnecessary burden on other segments of the U.S. immigration system. If USCIS were to revise the proposed rule as we suggest below, the provisional waiver process could further reduce the burden on the Executive Office for Immigration Review (“EOIR”) and on Immigration and Customs Enforcement (“ICE”). We note that while we are supportive of the comments previously submitted by the American Immigration Lawyers Association (“AILA”), we have chosen not to duplicate their comments here, but have instead focused on a few specific areas where we believe that we have something original and useful to add." - Cyrus D. Mehta & Associates, PLLC, June 1, 2012.