The Petitioner proposed to work as a financial manager providing individualized financial planning, business consulting, and investment strategy services to clients, including helping a facility maintenance company (B-S- LLC) attract Brazilian investment and structuring similar small businesses to attract international investors.

Prong 1 — national importancenot established · dispositive

“The issue here, however, is not the national importance of the field, industry, or profession in which the individual will work; instead we focus on the "the specific endeavor that the foreign national proposes to undertake."”

“we conclude the Petitioner has not shown that his proposed endeavor stands to sufficiently extend beyond his clientele to impact the financial management field, the financial services industry, or the U.S. economy more broadly”

“Without sufficient information or evidence regarding any projected U.S. economic impact or job creation attributable to his future work, the record does not show that benefits to the regional or national economy resulting from the Petitioner's financial management projects would reach the level of "substantial positive economic effects"”

“The letters from Dr. A-W- and Dr. M-I- do not contain sufficient information and explanation, nor does the record include adequate corroborating evidence, to show that the Petitioner's specific proposed work in financial management offers broader implications in his field or substantial positive economic effects for our nation that rise to the level of national importance.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “his skills, knowledge, and prior work in his field, however, relate to the second prong of the Dhanasar framework, which shifts the focus from the proposed endeavor to the foreign national”

  AAO decision text
• other · discounted

  “do not contain sufficient information and explanation, nor does the record include adequate corroborating evidence, to show that the Petitioner's specific proposed work...offers broader implications”

  AAO decision text
• other · credited

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
• Local, not national scope · p1 — impact confined to clients / a region

Notable

The AAO expressly distinguished the petitioner's occupation-level and field-level importance evidence (broad economic/finance industry articles, two professors' advisory opinions) from the specific-endeavor focus required under Dhanasar prong one, finding the advisory letters and general industry data insufficient despite conceding 'substantial merit.' The decision also notes each ground would independently support dismissal, though only prong one was actually reached.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

• INA 203(b)(2)
• Poursina v. USCIS

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