30-day Public Comment Response Matrix

Form I-590-013 Extension - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2007-0036
30-day FRN Citation (federalregister.gov): 90 FR 21325
Publish Dates: May 19, 2025 – June 18, 2025
Comment #
1.

Commenter Comment
ID
Commenter: CPAC Foundation Center for
Regulatory Freedom
0074
CRF opposes the renewal of Form I-590 and
instead recommends that USCIS conduct an
emergency revision of the form, as well as all
related rules, regulations, guidance, and
policies related to its use and
implementation. CRF urges USCIS to take
advantage of the current suspension of
USRAP and amend criteria for refugee status
determinations to deter further abuse and
fraud within the immigration system.
Recommendations:
Because Executive Order 14163 has
indefinitely suspended USRAP, USCIS now
has an opportunity to revise current
regulations and policy guidance overseeing
administration of the program and approvals
of refugee status. USCIS should act swiftly in
tightening agency rules and guidelines to
mirror the criteria reflected in landmark case
law, mainly the four-part test outlined in
Mogharrabi. Rather than referring to
individual instances of court determinations,
USCIS should rely on legal precedents that
have entrenched themselves in immigration
proceedings for decades, particularly those
reflecting the intentions and sentiments of
concrete legislation, such as the INA. Form I590 should be revised immediately to
increase the burden of proof required to
demonstrate a genuine fear of persecution.
The administrative burden associated with
refugee applications should also be increased
to de-incentivize fraudulent attempts to
claim refugee status as a faster means of
entry.
As of March 2025, there are an estimated
18.6 million illegal aliens residing in the
United States, despite massive deportation

USCIS Response

Response: This extension action is to
keep the form approved for use under
the Paperwork Reduction Act.

Form I-590-013 Extension - Responses to 30-day FRN Public Comments
Public Comments (regulations.gov): USCIS-2007-0036
30-day FRN Citation (federalregister.gov): 90 FR 21325
Publish Dates: May 19, 2025 – June 18, 2025
efforts and an increased presence of law
enforcement at the southern border. This
unmanageable influx of illegal aliens into the
United States over the last four years
demands that America’s national security
concerns be prioritized over the issuance of
humanitarian aid. If refugee admissions
continue to be conducted according to the
lowest possible threshold for what
constitutes a well-founded fear of
persecution, the nation’s immigration system
will continue to be infiltrated by those
seeking to take advantage of a more lenient
pathway into the country. USCIS should
narrow the current path to obtain refugee
status until the present illegal immigration
problem is under control.

2.

0075

See attachment in Comment ID 0074 for
additional details.
Commenter: Anonymous
This collection needs immediate attention
for termination based on regulatory
violations of authority. The agency that
originated this contract is not associated
with rule making. The excessive taxpayer
burden for this agreement is a result of
improper implementation of unlawful
contracts. Since 2003 this contract has been
in place and has multiple violations of the
law and is subject to additional legal impact
from this agreement currently in place.

Response: This extension action is to
keep the form approved for use under
the Paperwork Reduction Act.