MYTH OR REALITY: IS THE DHS TRULY SERIOUS ABOUT VISA MODERNIZATION FOR THE 21ST CENTURY?

"On November 21, 2014, as part of President Obama’s Executive Actions, the President issued a memorandum to modernize and streamline the U.S. immigrant and nonimmigrant visa system for the 21^st century.  The DHS followed up by publishing a notice in the Federal Register on December 30, 2014 inviting responses to 18 questions relating to visa modernization.  We responded in great depth to 2 of the 18 questions as they relate to what we have been advocating for several years to administratively fix the immigration system though big picture and out of the box ideas.  Our ideas are also included in the more expansive comments provided by the Alliance of Business Immigration Lawyers, and we salute all of the lawyers who were part of the comment team and who came up with the most innovative suggestions to modernize the visa system.  We  hope not without reason that this is not an exercise in futility, and that the DHS will seriously consider our ideas and those of our colleagues, including the weighty comments from the American Immigration Lawyers Association and other stakeholders in the immigration advocacy community. ... We reproduce, below, our comment..." - Gary Endelman & Cyrus D. Mehta, Feb. 2, 2015.