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  #181 (permalink)  
Old 01-07-2016, 12:54 PM
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Default Report violations to DHS\OIG and OPM

I encourage everyone to report this horrible person who was a former lobbyist and a current DHS employee who jeopardized lives of millions of law abiding skilled
immigrants.

Please report to
DHS OIG at
https://www.oig.dhs.gov/hotline/hotline.php

Also, this person has either not disclosed all information to a federal investigation officer at OPM who conducts background investigation for Security Clearance for
DHS. This is a crime and this person can be charged for lying or not disclosing information leading to a decision on her Security Clearance background investigation.

Please report to OPM also. In my honest opinion, it is OPM who is more responsible for this investigation than FBI
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  #182 (permalink)  
Old 01-07-2016, 01:18 PM
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Default 1k0-8n96-hgo9

I do not support this regulation in its current form and would like to register my opposition to the rule.. Please reinstate the provisions that our President originally intented to provide relief to the backlogged EB community

I strongly urge you to update the proposed rule to accomodate the following:

1. EAD's should be issued to all the approved I-140 holders with advance parole. There should be no compelling circumstances clause. Being stuck in the visa back log for years in itself is a compelling circumstance.

2. Job portability: An I-140 approved petition holder should not have to re-start PERM/I-140 after change of employment. This would be real job portability. Anything else is a step-backward.

3. EAD Renewal - There should be no condition of 1 year difference between priority date and visa cut-off date. This puts the EAD holder in jeopardy due to uncertainty in the visa cut-off dates. EAD's should be renewed automatically in 3 years increments when an extension has been filed.

4. Conduct an investigation of how this regulation changed from its original form in the last few months and any involvement of lobbyists and corruption
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  #183 (permalink)  
Old 01-07-2016, 01:36 PM
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Tweaked the last one slightly to avoid being flagged as a dupe 1k0-8n96-ee5x

Quote:
Dear Kevin,

As an EB3 Immigrant worker, I am writing to OPPOSE this rule.

The core issue Immigrant workers stuck in long backlogs are facing,- is unhealthy and unnatural dependence on the employer - and this 180 page regulation does absolutely nothing to make the employee independent of the employer.

DHS has the authority to issue EAD and Advance Parole to Immigrant workers with approved immigration petitions stuck in these backlogs, while making sure they move through the immigration process as priority dates become available and not requiring redundant re-filing of Labor certifications/I-140. DHS can continue issuing EAD's until the eventual adjudication of their I-485 application - without insisting on "Compelling Circumstances" or putting any artificial restrictions on their career and personal growth.

In fact, the above was the intent behind the President's Executive order in November 2014, when he ordered a modernization of the Legal Immigration System. No other modern western industrialized country keeps legal immigrants in an extended state of Visa limbo or treats them like indentured servants like the United States does.

Additionally, creating a two tiered class system of workers in the American Labor market creates incentives for employers to prefer hiring workers with less rights - i.e. workers on H1-B visa's as opposed to American workers. Companies underpay their American workers by using the implicit threat of replacing them with lower paid guest workers on H1-B (and L1) visas. Companies have lobbied very hard to create, preserve and protect this two tiered class system of workers.

Given how hard Companies have worked to maintain this system and how much they benefit from the lack of job mobility with their H1-B workers, I have the following fair and reasonable questions for you about THE former top Immigration lobbyist, formerly in the employ of the TOP Corporate lobbying organization, the U.S. Chamber of Commerce - who joined DHS in September 2015. I want to know:
1. This IMMIGRATION lobbyist was allowed to write regulations on IMMIGRATION in DHS. Why was this lobbyist allowed to write regulations on a subject they were lobbying on literally until the week before they joined DHS?
2. Why the lobbyist was allowed join DHS right after leaving the Chamber of Commerce without a cool-off period?
3. Why did this lobbyist and a senior DHS official visit the U.S. Chamber of Commerce shortly after the lobbyist joined DHS? Is such contact between the lobbyist and their former employer appropriate? Is it legal? Proof of this visit can be found in the following link: https://www.uschamber.com/sites/defa...final_-_v2.pdf

Given the strong STINK of impropriety (not to mention that the rule directly contravenes a Presidential Executive order), I would like to humbly and respectfully request an FBI investigation into the process that went into the drafting of this rule, namely if promises of employment (or other enticements) were made to DHS employees by the U.S. Chamber of Commerce. I also would like to request that the FBI probe the visit where the Lobbyist and the senior DHS official visited the U.S. Chamber of Commerce. Additionally, I think it only fair that the FBI keep track of the careers of other employees associated with the drafting of this rule and see if any of them end up at the U.S. Chamber of Commerce or related entities when the current Administration demits office.
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  #184 (permalink)  
Old 01-07-2016, 01:38 PM
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I think it is a great idea to paste a copy of your submission here, just like hil3182 did. We can mix and match and create lots of unique comments from the repertoire.

Whatever you do, begin your comments explicitly mentioning that- I REJECT this proposed rule
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  #185 (permalink)  
Old 01-07-2016, 01:50 PM
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Quote:
Originally Posted by hil3182 View Post
It is very important to get the word out, that people explicitly "Reject" the Rule in the first line of all comments - or DHS might score it as a positive comment and we will not get the changes we want.
Hi hil....question - how is it that this rule has been approved by the OMB? The OMB sits within the White House and if what's proposed is not aligned to the President's vision the OMB will not approve it but they have....That being the case, what gives? Why has the OMB approved this rule that even remotely does not match what the president mentioned in his stump for EO? We have been sold for cheap in the barter that's happened....and the WH approves this. Comments?
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  #186 (permalink)  
Old 01-07-2016, 01:53 PM
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OMB has not approved the rule. It has approved the proposed rule to be published for comments by stakeholders. Please comment on this version of the rule, and send it back to DHS for good.
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  #187 (permalink)  
Old 01-07-2016, 01:53 PM
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Quote:
Originally Posted by RH_93 View Post
Hi hil....question - how is it that this rule has been approved by the OMB? The OMB sits within the White House and if what's proposed is not aligned to the President's vision the OMB will not approve it but they have....That being the case, what gives? Why has the OMB approved this rule that even remotely does not match what the president mentioned in his stump for EO? We have been sold for cheap in the barter that's happened....and the WH approves this. Comments?
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.
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  #188 (permalink)  
Old 01-07-2016, 01:58 PM
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Quote:
Originally Posted by hil3182 View Post
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.
Got you..thanks much !
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  #189 (permalink)  
Old 01-07-2016, 02:00 PM
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Quote:
Originally Posted by hil3182 View Post
We have the sold down the river and the WH either - didn't think we were worth fighting for or people in the WH were bought too. There is no doubt that they knew what was going on.

Either way, if we stay quiet, nothing is going to happen. They thought we would stay quiet and be thankful for the peanuts they threw at us - we need to upset that calculation.
Pardon my unawareness, but out of curiosity I was wondering is there a precedent where the DHS or whatever dumbfuck agency has produced this garbage would change it solely based on the comments.
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  #190 (permalink)  
Old 01-07-2016, 02:00 PM
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Quote:
Originally Posted by RH_93 View Post
Got you..thanks much !
You are welcome. Please comment on the rule and start every comment with a firm and clear rejection of the rule.

If you aren't explicit about your rejection, the slime-balls might mark your comment as being a positive comment.
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  #191 (permalink)  
Old 01-07-2016, 02:04 PM
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Default Your Comment Tracking Number: 1k0-8n96-g7ut

I completely OPPOSE the proposed rule in its current form.
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  #192 (permalink)  
Old 01-07-2016, 03:11 PM
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Default Excerpt from USCIS/DHS regulatory impact analysis

If this helps framing comments -

Labor market impacts - Finally, DHS assumes that the proposed rule may negatively impact some U.S. employers who sponsor workers for employment-based immigrant visas, primarily through higher rates of employee turnover due to accepting offers of employment with other employers. Employers incur costs by filing an employment-based immigrant visa petition on an employee’s behalf when seeking to sponsor that employee for lawful permanent residence. However, employers may view the costs associated with sponsoring an employee as a tangible investment in the company. At the same time, if the principal beneficiary of the immigrant visa petition pursues unrestricted employment authorization under this rule and changes employers, the petitioning employer could incur some turnover costs. Consequently, increased rates of employee turnover may occur as certain nonimmigrant workers pursue unrestricted employment authorization.

Benefits - The finalized rule would grant a newly created benefit of permitting certain nonimmigrant workers who face compelling circumstances, as well as their dependents, to apply for unrestricted employment authorization. The ability to obtain these employment authorizations increases incentives to nonimmigrant workers who have begun the process of becoming LPRs and find themselves under difficult circumstances to remain in and contribute to the U.S. economy as they complete the LPR process. The lengthy timeframes and lack of flexibility in the process of becoming an LPR can be discouraging and drive many high-skilled nonimmigrant workers to abandon their pursuit of permanent status. The unrestricted employment authorizations are an attractive benefit in retaining these high-skilled workers as they wait to become LPRs, especially when those workers are faced with compelling circumstances that might otherwise cause them to abandon their efforts. These EADs allow such high-skilled workers to continue to progress in their careers by allowing flexibility in accepting offers of employment, with their current employer or with a new employer, while maintaining their position in the queue for visa availability. Retaining these high-skilled nonimmigrant workers who intend to become LPRs is important when considering the contributions of these individuals to the U.S. economy, including advances in entrepreneurial, research and development endeavors. Moreover, the ability to pursue new career choices does not eliminate the requirement for such workers to have a new employer petition on his or her behalf for permanent employment.
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  #193 (permalink)  
Old 01-07-2016, 03:16 PM
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Quote:
Originally Posted by hil3182 View Post
Tweaked the last one slightly to avoid being flagged as a dupe 1k0-8n96-ee5x
So Did I.

Dear Mr. Kevin,

I am writing to show my strong REJECTION to this rule in it's current format.

The basic plight of an Highly Skilled Worker is that he is stuck in long backlogs caused by multiple reasons- per country quota limit, agency's incompetence to utilize all visas over the years; causing dependence on employer, thus forfeiting any natural career progression and ability to start own business and possibly employ US Citizens. This 180 page rule does nothing to circumvent this, as it was intended initially in President's Executive Order.

DHS has the authority to issue EAD and Advance Parole to Immigrant workers with approved immigration petitions (I-140) stuck in these backlogs, while making sure they move through the immigration process as priority dates become available and not requiring redundant re-filing of Labor certifications/I-140 and thus helping grow in career, switch employers at will. DHS can continue issuing EAD's until the eventual adjudication of their I-485 application. This, being anchored to a single employer, can be relieved.

In fact, the above was the intent behind the President's Executive order in November 2014, when he ordered a modernization of the Legal Immigration System. No other modern western industrialized country keeps legal skilled immigrants in such a matrix of unreality and treats them like indentured servants like the United States does.

This also creates a classifications of workers in same field. Ones who have limited rights and others who are US citizens. This entices US employers to exploit both classes; keeping US citizen workers accept lower rates of wages in fear of being replaced by H1Bs. And immigrant workers being pressurized to work at lower rates by limiting their rights to move around in jobs. This is a great motivational factor for employers to not allow immigrant employees to have freedom to switch jobs as it builds up their bottom line.

Given how hard Companies have worked to maintain this system and how much they benefit from the lack of job mobility with their H1-B workers, I have the following fair and reasonable questions for you about THE former top Immigration lobbyist, formerly in the employ of the TOP Corporate lobbying organization, the U.S. Chamber of Commerce - who joined DHS in September 2015. I want to know:
1. Why this IMMIGRATION lobbyist was allegedly allowed to write or influence regulations on IMMIGRATION in DHS, swaying the original intent of regulation in a way that does not conform to The President's EO at all.
2. Why the lobbyist was allowed join DHS right after leaving the Chamber of Commerce without a cool-off period?
3. Why did this lobbyist and a senior DHS official visit the U.S. Chamber of Commerce shortly after the lobbyist joined DHS? Is such contact between the lobbyist and their former employer appropriate? Is it legal? Proof of this visit can be found in the following link: https://www.uschamber.com/sites/defa...final_-_v2.pdf

With this conflict of interest, I would like to request an FBI investigation into the process that went into the drafting of this rule, namely if promises of employment (or other enticements) were made to DHS employees by the U.S. Chamber of Commerce. I also would like to request that the FBI probe the visit where the Lobbyist and the senior DHS official visited the U.S. Chamber of Commerce. Additionally, I think it only fair that the FBI keep track of the careers of other employees associated with the drafting of this rule and see if any of them end up at the U.S. Chamber of Commerce or related entities when the current Administration demits office.
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  #194 (permalink)  
Old 01-07-2016, 03:24 PM
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Looks like someone communicated about the meeting link to chamber of commerce. Page from the link got removed.
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  #195 (permalink)  
Old 01-07-2016, 03:34 PM
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Default Interesting comments

Found this. Please check "Adjustment of Status Applcations" part

Regulations.gov
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