THE DIRECTOR OF SELECTIVE SERVICE
Arlington, Virginia 22209•2425
August 30, 2018
The Honorable
L.
Francis Cissna, Director
U.S. Citizenship and Immigration Services
111
Massachusetts Ave. Headquarters Building
Washington, D.C. 20529-2180
Dear Director Cissna:
I am writing
to
you directly because my staff has been unable to identify a USCIS
liaison officer with Selective Service
or
anyone else at USCIS to submit our request to.
We
are requesting that the Instructions to the Application for Naturalization be
slightly revised
to
reflect the information requested on USCIS Application
N~turalization Form N-400 regarding Selective Service System registration.
USCIS Form N-400, Part 12 (44)(c)(2), only asks applicants age 26 to
31
to
provide a "status information letter'' (SIL) from Selective Service,
if
they did not
register. However, the Instructions for Form N-400 asks applicants age 26 or older
who were required
to
register but did not, to provide proof
of
registration and a status
information letter from Selective Service.
The requested revisions would also make the instructions consistent with USCIS
policy. Moreover,
it
will help reduce numerous unnecessary requests
to
Selective
Service for 1,000s
of
Status Information Letters (SILS) from applicants over age
31
because they are eligible for naturalization even
if
the applicant knowingly and willfully
failed
to
register (USCIS Policy Manual - Volume 12 - Part D - Chapter 7, which states
that "Applicants over age 31 are eligible for naturalization even
if
the applicant
knowingly and willfully failed
to
registet').
Suggested Revisions to the INSTRUCTIONS:
(Edits are made with red print and stricken language (page 13):
F. Selective Service Registration.
If
you are a man between 18
and~
31
years
of
age, provide proof
of
your registration with the Selective Service.
If
you are 26 and years
of
age or older, provide proof that you registered
with the Seleotive
SeFYise
•.vhen
you were required to do so
bet\•.•een
18
and 26 years of age. Note: By law, a person cannot register once they
tum age 26.
If
you between 26 to
31
years
of
age
If
you were required to register and
did not register, provide a typed or printed statement explaining why you
did not register and provide a ~status information letter
lt
from the Selective
Service. The letter will only determine whether you were required
to
register.
If
you age
31
or
older, there
is
no requirement
to
provide a status
information letter from Selective Service
or
any other paperwo
rk.
regarding
Selective Service registration -
No
action is required
or
requested.
For more information about Selective Service registration,
or
how
to
get
proof that you registered, visit www.sss.gov
or
call 1-888-655-1825.
Correcting the Instructions to would reduce the administrative costs
of
Selective
Service
of
preparing and sending thousands
of
SILs to men over age
31
who
request
them unnecessarily. It would also reduce the USCIS administrative costs
by
not have to
process them, including having to read unnecessary statements from applicants over
age 31.
It
is our understanding that the "instructions" for completil"'!g forms do not need to
be approved by
0MB
- only forms need
0MB
approval. So the requested revisions to
the online instructions to Form N-400 could be done very quickly.
Thank you for your assistance in this matter.
If
you have any questions,
or
need
additional information, please contact me
at
703-605-4010; [email protected],
or
Mr. Rudy Sanchez, General Counsel,
at
703-605-4012; [email protected].
U:~
-~
Donald M. Benton
Enclosures:
1.
USCIS Application Naturalization form N-400, Part 12 (44)(c)(2)
2.
Instructions
to
the Application for Naturalization
3.
USCIS Policy Manual - Volume
12
- Part D - Chapter 7
Mr. Donald M. Denton
Director
of
Selective Service
1515 Wilson Boulevard
Arlington, Virginia 22209-2425
Dear
Mr.
Benton:
November 5, 2018
U.S.
Depurlmcnt
of
Homelnnd
Security
U.
S.
Citi
ze
nship n
nd
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gra
ti
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rvices
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· (MS
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Wu
s
hin
gton, DC
20529
-2000
U.S.
Citizenship
and
Immigratfon
Services
Thank you for your August 30, 2018 letter regarding the Form N-400 instructions and the.
language on Selective Service. '
'-"
·
''
U.S. Citizenship and Immigrntion Services (USCIS)
is
currently considering changes to
form
N-400, Application for Naturalization, and wiJl make edits indicating that
if
an applicant is
over
31
years
of
age (or over
29
years
of
age
if
applying based
on
being the spouse
of
a U.S.
citizen) at the time the
form
N-400 is filed, the applicant does not need to provide a status
information letter
or
a statement explaining the reason for
not
registering. A 60-day f edcral
Register Notice will be published to provide the public with an opportunity to comment on the
proposed changes. USCIS
will
confirm the edits to the Selective Service language with your
agency once the Notice publishes. ·
Sincerely,
L. Francis Cissna
Director
www.uscls.gov