The Petitioner sought to operate a Florida-based financial consulting company facilitating wealthy Brazilian investors' access to U.S. financial products and services, including ATM revenue-sharing and insurance/annuity offerings.

Prong 1 — national importancenot established · dispositive

“The Petitioner must establish the national importance of the specific proposed endeavor, rather than the overall importance of a particular industry, occupation, or field.”

“These claims are inconsistent as to whether the company would serve U.S. clients.”

“The business plan projected sharp increases in revenues in future years but did not cite specific evidence to support those projections.”

“This substantial discrepancy casts significant doubt on the accuracy of the business plan.”

“This arrangement benefits [] by increasing its client base, and the resulting commissions benefit the Petitioner's company, but the Petitioner did not establish that her company's activities under the agreement have broader implications that demonstrate national importance.”

“The information in the record indicates that the Petitioner's company has had a very limited economic impact, and does not indicate that the company has created any jobs for U.S. workers.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “This substantial discrepancy casts significant doubt on the accuracy of the business plan.”

  AAO decision text
• contract revenue · discounted

  “the Petitioner did not establish that her company's activities under the agreement have broader implications that demonstrate national importance.”

  AAO decision text
• recommendation letter · discounted

  “This letter indicates that the Petitioner's company helped this customer, but it does not establish the broader implications of the proposed endeavor.”

  AAO decision text
• other · discounted

  “The reports and articles do not describe or address the Petitioner's specific proposed endeavor.”

  AAO decision text

Where this case turned

• Business plan speculative · p1 — projections without a documented basis or steps
• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO relied heavily on internal inconsistencies between the business plan's projected revenues/capital and actual tax return figures, and on the Petitioner's documented outside employment (private banking, financial advisor role) as evidence undermining the endeavor's genuineness and national importance; declined to reach prongs 2 and 3 under Bagamasbad/L-A-C- doctrine.

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.

• 8 C.F.R. 103.3
• 8 C.F.R. 204.5(k)(2)
• Matter of Ho
• Matter of L-A-C-
• Poursina v. USCIS

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