The Petitioner proposed to create a financial consultancy company in Florida offering financial documentation, tracking systems, and fiscal stability services to small and medium-sized U.S. businesses, aiming to ease their access to business loans.

Prong 1 — national importancenot established · dispositive

“the record does not include detailed and thorough plans to reach beyond her company to make a national impact”

“Although these articles demonstrate the national importance of financial analytics and consultants, the matter here is not whether financial analytics and consultants are nationally important.”

“Generalized conclusory statements that do not identify a specific impact in the field have little probative value.”

“growth of the industry and financial analyst occupations does not render her proposed endeavor nationally important under the Dhanasar framework”

“the Petitioner did not present any supporting evidence, corroborating the assertions and figures”

“the Petitioner did not establish the significance of this data to show that the benefits to the regional or national economy would reach the level of "substantial positive economic effects"”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the Petitioner did not present any supporting evidence, corroborating the assertions and figures”

  AAO decision text
• recommendation letter · discounted

  “does not explain, other than generalized statements, how the Petitioner's particular services would have broader implications for our country”

  AAO decision text
• other · discounted

  “relate to the influence her company would have on those specific clients and companies, not the far reaching or national impact of her company”

  AAO decision text
• other · discounted

  “growth of the industry and financial analyst occupations does not render her proposed endeavor nationally important under the Dhanasar framework”

  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
• 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
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

AAO explicitly declines to reach prongs 2/3 or the underlying EB-2 classification, and states each stated reason is an independent and alternate basis for dismissal. Cites Flores v. Garland regarding discretionary nature of NIW grants.

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
• Matter of L-A-C-

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