An April 12, 2002 INS field memo provides guidance on how the term "course of study" will be interpreted by INS for purposes of the regulatory restriction created by a rule published on April 12, 2002 at 67 Fed.Reg. 18061.

The memo states:

"The term "course of study" implies a focused program of classes, such as a full-time course load leading to a degree or, in the case of a vocational student, some type of certification. Casual, short-term classes that are not the primary purpose of the alien's presence in the United States, such as a single English language or crafts class, would not constitute a "course of study." Courses with more substance or that teach a potential vocation, such as flight training, would be considered part of a "course of study" and thus would require approval of a student status." AMDOC#: 200209016