MAY302024_02B5203Decided 2024-05-30I-140

A financial manager's EB-2 National Interest Waiver petition was dismissed because the proposed small-business advisory…

Dismissed Useful for: avoid these mistakes
EB-2-NIWField: administrative and financial advisement for small and medium-sized businesses
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal, finding the petitioner failed to establish national importance of the proposed endeavor under the first Dhanasar prong, and also withdrew the Director's finding that the petitioner was well-positioned under the second prong.

In plain English

The petitioner, a financial manager, sought an EB-2 National Interest Waiver to establish a firm providing financial and administrative advisory services to small and medium-sized businesses hurt by COVID-19. The Texas Service Center Director denied the petition, finding no national importance but accepting that the petitioner was well-positioned. On de novo review, the AAO agreed there was no national importance—the proposed services would benefit only the petitioner's direct clients, not the broader economy—and additionally withdrew the Director's favorable finding on well-positioning, noting the record lacked credible evidence of meaningful progress or relevant support from investors or clients. Because two of the three Dhanasar prongs were unmet, the AAO dismissed the appeal without reaching the third prong.

What worked & what failed

What failed: 1. The proposed endeavor—providing financial advice to local small businesses—was found to benefit only direct clients, not the national economy broadly, similar to how teaching benefits only enrolled students. 2. The business plan's projected hiring of 13 employees and modest tax revenue was too small-scale to demonstrate substantial positive economic effects at a national level. 3. Expert opinion letters and client recommendation letters were too generic or internally inconsistent to demonstrate national importance or meaningful well-positioning.

Takeaway: For an EB-2 NIW in financial services, petitioners must articulate and document concrete broader economic or societal implications of their work—not just the value to individual clients. Evidence such as policy influence, industry-wide innovations, or independently verifiable large-scale economic impact is needed to satisfy the national importance prong.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-2-NIW criteria.

Evidence that moved the needle

  • See summary above for details.

Evidence that wasn't enough alone

  • The proposed endeavor—providing financial advice to local small businesses—was found to benefit only direct clients, not the national economy broadly, similar to how teaching benefits only enrolled students
  • The business plan's projected hiring of 13 employees and modest tax revenue was too small-scale to demonstrate substantial positive economic effects at a national level
  • Expert opinion letters and client recommendation letters were too generic or internally inconsistent to demonstrate national importance or meaningful well-positioning.
Find more EB-2-NIW cases with similar evidence patterns →
Evidence that persuaded the AAO

Advanced degree qualification — the Director's finding that petitioner qualifies as an advanced degree professional was undisturbed.

Where the evidence fell short

Three articles on the importance of small and medium-sized businesses to the U.S. economy — did not demonstrate broader national implications of the petitioner's specific proposed endeavor.

Expert opinion letters commissioned by the petitioner — discussed general importance of the industry and petitioner's background but did not analyze the broader implications or national importance of the proposed endeavor; one letter contained a conflicting name reference undermining its reliability.

Three recommendation letters from prior clients — described competent services rendered but did not establish prospective national-level impact beyond the individual businesses served.

Business plan projecting 13 employees and $162,745 in tax revenue over five years — insufficient to show substantial positive economic effect commensurate with national importance.

Company registration and ongoing operation — insufficient as evidence of meaningful progress toward the proposed endeavor.

Officer errors the AAO found

The Director incorrectly found the petitioner was well-positioned to advance the proposed endeavor under Dhanasar prong two; the AAO withdrew this finding.

How the case moved

Completed

I-140 filed

Financial manager seeking to establish a firm providing financial and administrative advisory services to small and medium-sized businesses

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2024-05-30

AAO decision — Dismissed

The AAO dismissed the appeal, finding the petitioner failed to establish national importance of the proposed endeavor under the first Dhanasar prong, and also withdrew the Director's finding that the petitioner was well-positioned under the second prong.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

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Authorities the office relied on
8 C.F.R. § 103.3
DhanasarEstablishes the three-prong framework for adjudicating national interest waiver petitions.
ChawathePetitioner bears burden of proof by preponderance of the evidence.
Christa's Inc.AAO reviews questions de novo.
Flores v. GarlandUSCIS decision to grant or deny a national interest waiver is discretionary in nature.
Matter of Y-B-Burden of proof includes both burden of production and burden of persuasion.
Caron Int'lExpert opinion letters are advisory and not presumptive evidence of eligibility; doubt in any aspect of the opinion reduces its weight.
Matter of HoDoubt cast on any aspect of a petitioner's proof may lead to doubts about the reliability and sufficiency of remaining evidence.
BagamasbadCourts and agencies need not make findings on issues unnecessary to the result they reach.
Matter of L-A-C-Declining to reach alternative issues on appeal where applicant is otherwise ineligible.