The Petitioner, a treasurer/controller with 28+ years of experience, proposed to continue in the finance field in the U.S., later specifying he would serve as managing partner and CFO of his own Florida-based financial consulting firm offering audit, controls, tax, and advisory services.

Prong 1 — national importancenot established · dispositive

“these employment and revenue projections are not supported by details showing their basis, nor do they sufficiently demonstrate a significant potential to either employ U.S. workers or to substantially impact the regional or national economy”

“the Petitioner has not offered sufficient evidence to establish that his business would operate in a HUBZone area”

“While the Petitioner proposes to work in an important industry or field, this is not necessarily sufficient to establish the national importance of the specific proposed endeavor”

“the letters of recommendation do not offer persuasive detail concerning the impact of his proposed endeavor and how it would extend beyond his clients”

“the Petitioner has not provided evidence demonstrating that his proposed business activities would operate on such a scale as to rise to a level of national importance”

AAO decision text

How the evidence was treated

• business plan · discounted

  “these employment and revenue projections are not supported by details showing their basis”

  AAO decision text
• recommendation letter · discounted

  “the letters of recommendation do not offer persuasive detail concerning the impact of his proposed endeavor”

  AAO decision text
• resume experience · discounted

  “the Petitioner's expertise and record of success in previous positions are considerations under Dhanasar's second prong”

  AAO decision text
• media · discounted

  “the articles and reports do not discuss any particulars of the Petitioner's proposed endeavor or its prospective impact”

  AAO decision text
• degree · discounted

  “based upon the information in EDGE and the length of the program as reflected in the transcript, we question its accuracy”

  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
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact

Notable

AAO withdrew the Director's finding on substantial merit but still found no national importance. In a footnote, the AAO raised sua sponte a threshold eligibility concern (foreign degree equivalency) not relied upon by the Director, questioning an academic evaluator's conclusion using the AACRAO EDGE database, but expressly reserved the issue since prong 1 was dispositive. Also noted was a material-change concern: the petitioner's own company/CFO role was not part of the endeavor as described at filing but arose ~2 years later in response to a NOID.

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)
• Flores v. Garland
• Matter of Izummi

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