dismissedMAR142025_06B52032025-03-14 · appeal · Texas Service Center
This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.
The Petitioner, a Brazilian lawyer, proposed to operate a consulting firm as CFO/CEO offering B2B consulting services to U.S. banks and financial institutions seeking to enter the Brazilian mortgage and real estate market, including training and advisory services.
Field: law / mortgage-and-real-estate consulting · Read the decision (uscis.gov)
Prong 1 — national importancenot established · dispositive
“they do not discuss the specific impact of the Petitioner's consulting services on the mortgage industry or field as a whole”
“the relevant question here is not the importance of the industry or profession in which the individual will work”
“the letter lacks specific examples as to how a lone consulting company can make such substantial economic impact to the field”
“the record does not include any evidence-based justifications for its staffing projections and the need to hire additional employees”
“the Petitioner has not demonstrated that the proposed endeavor extends beyond her future clients, to impact the field or any other industries more broadly”
AAO decision text
How the evidence was treated
- other · discounted
“they do not discuss the specific impact of the Petitioner's consulting services on the mortgage industry or field as a whole”
AAO decision text - recommendation letter · discounted
“the letter lacks specific examples as to how a lone consulting company can make such substantial economic impact to the field”
AAO decision text - business plan · discounted
“the record does not include any evidence-based justifications for its staffing projections and the need to hire additional employees”
AAO decision text - degree · ignored
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
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Notable
In footnote 3, the AAO observes that the Director had found the Petitioner well-positioned under prong 2 without providing analysis, and expressly declines to resolve whether her background as a business lawyer makes her well-positioned to work as CEO of a mortgage consulting company, reserving the issue for future consideration.
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
- Flores v. Garland
- INA 203(b)(2)
- Matter of E-M-
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