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MGC's Response to the USCIS Request for Feedback

Updated: May 19


The United States Citizenship and Immigration Services asked for feedback about the impact of their policies. Now, they didn't do this out of the goodness of their own heart. The president told them to.


MGC has submitted testimony on this issue with our focus on how USCIS policies impact genealogists. We have many member societies. With American Ancestors/NEHGS among them, we speak for thousands of genealogists. This is what we said on your behalf.


May 17, 2021


The Honorable Tracy L. Renaud Senior Official Performing the Duties of Director United States Citizenship and Immigration Services United States Department of Homeland Security 20 Massachusetts Avenue NW Washington, DC 20529-2140


RE: DHS Docket No. USCIS-2021-0004, USCIS Genealogy Program


Dear Ms. Renaud,

We are grateful for President Biden’s Executive Order 14012, “Restoring Faith in Our Legal Immigration Systems and Strengthening Integration and Inclusion Efforts for New Americans.” We are happy that USCIS is following through on this order by seeking feedback on strategies for “fair, efficient adjudications of these benefits.” Thank you for soliciting feedback and for your consideration of our comments.


The Massachusetts Genealogical Council (MGC) is an umbrella organization representing sixteen organizations within our state. Our member societies range in size but in total we represent nearly 35,000 genealogists using their family histories to understand their place here in America.


Genealogists are perturbed that files (N1-566-04-003 and N1-566-04-004) which were scheduled for transfer to the National Archives and Records Administration in 2019 but are not yet transferred. We can access NARA records for free. USCIS’s policy to keep these older records in their own purview adds costs and delays. Right now, records from the Genealogy Program take three times longer to process than a FOIA request.


We at the Massachusetts Genealogical Council urge the US Citizenship and Immigration Services to implement the best Records Management plans possible going forward. Using professional standards should ensure that USCIS no longer falls more and more behind each year in meeting its records transfer goals. Finishing the index to the older A files should result in quicker index lookups for USCIS staff. Quicker index lookups should result in decreased time used for each records request. Quicker handling of requests should result in a lower backlog. Record requests would be fulfilled in 15 minutes rather than 2 hours. This would benefit the genealogists who are members of our member societies.


Sincerely yours, Barbara Jean Mathews

president@massgencouncil.org PO Box 5393 Cochituate, MA 01778

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