NAFSA Comments On Proposal To Include Deemed Export Attestation On Form I-129

April 05, 2010 By: NAFSA Download pdf

On April 5, 2010, NAFSA submitted a comment letter on the USCIS proposal to add a deemed export compliance attestation on Form I-129. You can access a draft copy of the proposed Form I-129 on the NAFSA Web site.

Public comments on the revisions to Form I-129 are due April 9, 2010. NAFSA encourages members to comment on the proposal as well, following their own institution's protocols for submitting comments to Federal Register notices. Since deemed export control is generally not handled by international services offices, you may consider inquiring with your federal relations or general counsel's office about whether your institution is planning to comment on the proposal.

In its comment letter, NAFSA focused on the fact that an attestation on Form I-129 will unnecessarily burden not only schools that are active in sensitive technology fields, but schools that aren't as well. Although NAFSA's comments are limited to the deemed export attestation proposal, USCIS is also proposing additional changes to Form I-129 (see USCIS's table of proposed changes for more detail).

For developments on the issue, refer to NAFSA's I-129 deemed export advisory