The undersigned members of the ICLN and other interested parties are writing in response to the regulations proposed by U.S. Citizenship and Immigration Services (“USCIS”) on September 6,
2011, regarding Special Immigrant Juvenile Petitions. While we applaud the proposed
regulations’ provisions reflecting the statutory language updated by the William Wilberforce
Trafficking Victims Protection Reauthorization Act of 2008, we have significant concerns about
much of the proposed regulatory language, as well as the commentary accompanying the
proposed regulations. We urge you to amend the proposed regulations in the following manner.
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