The Petitioner, a banking and finance professional with prior experience at a Colombian bank, proposed to operate a Florida-based financial consulting company offering services such as risk management, regulatory compliance, financial literacy training, and market entry strategies to small businesses, entrepreneurs, and underserved low-income populations.

Prong 1 — national importancenot established · dispositive

“The Petitioner did not provide specific plans, projections or calculations in support of his broad claims regarding the potential indirect economic or "ripple" effects of his proposed endeavor.”

“As observed by SCOPS, the Petitioner did not explain how the services he intends to provide would have economic effects that extend beyond those clients”

“A shortage of qualified professionals alone does not render the work of an individual financial consultant nationally important under the Dhanasar precedent decision.”

“The authors do not discuss his specific proposed endeavor or explain, for example, how the Petitioner's past work would be carried over to the proposed endeavor”

“he does not sufficiently address the Petitioner's specific proposed endeavor as it is described elsewhere in the record”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the plan does not otherwise indicate that services in this sector would be a main focus of the endeavor”

  AAO decision text
• contract revenue · discounted

  “does not explain how these financial and staffing projections are at a level that demonstrates national importance”

  AAO decision text
• recommendation letter · discounted

  “they do not do so with specificity and therefore are not probative of the Petitioner's eligibility under the first prong”

  AAO decision text
• other · discounted

  “much of the content of the expert opinion letter lacked relevance and probative value with respect to the national importance”

  AAO decision text
• resume experience · discounted

  “the Petitioner's knowledge, skills, education, and experience are considerations under Dhanasar's second prong”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
• Letters not independent · p1 — letters come from employers and close collaborators, not independent experts
• Local, not national scope · p1 — impact confined to clients / a region
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

The AAO found the Petitioner's expert opinion letter unpersuasive because it described a different, broader endeavor (bank restructuring/HR consulting) than the one actually detailed in the Petitioner's own business plan (a small consulting firm). The decision also rejects a 'research and development' framing of the endeavor asserted only in a cover letter but unsupported by the actual professional plan.

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)
• Flores v. Garland
• INA 203(b)(2)
• Matter of Caron Int'l
• Matter of D-R-

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