The Petitioner, a chief financial officer, proposed to offer her financial expertise generally to U.S. companies of any size by developing and implementing financial plans and growth projects, without identifying a specific employer.

Prong 1 — national importancenot established · dispositive

“There is no evidence that the 'ecosystem' of the United States financial sector will be affected by the [Petitioner's] employment or lack thereof.”

“the relevant question is not the importance of the industry, field, or profession in which an individual will work”

“The generalized proposal to determine and formulate policies and provide "overall direction" of an entity does not establish how the endeavor would have broader implications”

“describing the endeavor as "developing and implementing financial plans, creating opportunities for growth, and developing and implementing projects to realize that growth" does not establish how the plans and projects would create growth”

“the [Petitioner's] financial officer activities are unlikely to offer benefits that extend beyond her immediate employer to impact the field of finance broadly.”

AAO decision text

Where this case turned

• 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

Notable

The Petitioner did not identify a specific prospective employer, describing the endeavor only in generic CFO terms; on appeal the Petitioner argued broadly about CFOs as a profession (diversity trends, access to data) rather than her specific endeavor, which the AAO found did not address the Director's employer-specific-benefit concern.

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)

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