The petitioner, an actuary, proposed to establish and serve as CEO/actuarial consultant of his own insurance consulting services business in Florida and New York, offering risk assessment and brokerage support services.

Prong 1 — national importancenot established · dispositive

“The Petitioner's reliance on his academic credentials, achievements, and professional experience to establish the national importance of his proposed endeavor is misplaced.”

“The Petitioner has not provided corroborating evidence, aside from claims in his statements and his business plan, that his business's activities stand to provide substantial economic benefits to the United States.”

“The record does not sufficiently detail the basis for its financial and staffing projections, or adequately explain how these projections will be realized.”

“The content of the opinion is lacking relevance because it discusses how the Petitioner's expertise would be beneficial to U.S. companies doing business in Brazil”

“merely working in the insurance field or starting an insurance consulting business is insufficient to establish the national importance of the proposed endeavor”

AAO decision text

How the evidence was treated

• business plan · discounted

  “it does not document the potential prospective impact, including the asserted economic benefits to the United States”

  AAO decision text
• recommendation letter · discounted

  “Where an opinion is not in accord with other information or is in any way questionable, USCIS is not required to accept it or may give it less weight.”

  AAO decision text
• media · discounted

  “The industry reports and articles submitted do not discuss any projected U.S. economic impact or job creation specifically attributable to the Petitioner's proposed endeavor.”

  AAO decision text
• resume experience · discounted

  “his reliance on his academic credentials, achievements, and professional experience to establish the national importance of his proposed endeavor is misplaced”

  AAO decision text
• degree · credited

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
• 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

Notable

AAO declined to consider a materially different endeavor (working for any company or individual) first raised on appeal, limiting review to the originally proposed business, citing Matter of Izummi and 8 C.F.R. 103.2(b)(1) regarding impermissible post-filing material changes.

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. 103.2(b)(1)
• 8 C.F.R. 103.3
• 8 C.F.R. 204.5(k)(2)
• Matter of Caron Int'l
• Matter of D-R-
• Matter of E-M-
• Matter of Izummi
• Matter of L-A-C-
• Poursina v. USCIS

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