The Petitioner, a CFO and corporate treasurer, proposed to start a financial and strategic consulting firm in Ohio offering personal financial planning, investment management, business consulting, retirement planning, and tax consulting, with a focus on serving immigrants.

Prong 1 — national importancenot established · dispositive

“This evidence establishes the importance of the financial services industry.”

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

“the record does not show that the Petitioner's proposed endeavor stands to sufficiently extend beyond her clientele to impact the financial services industry more broadly”

“the Petitioner has not shown how the proposed endeavor's claimed employment projections have significant potential to employ U.S. workers”

“operating a business in an area that is adjacent to the subject of national initiatives is not sufficient, in and of itself, to establish the national importance”

AAO decision text

How the evidence was treated

• business plan · discounted

  “operating a business in an area that is adjacent to the subject of national initiatives is not sufficient, in and of itself”

  AAO decision text
• other · discounted

  “this evidence is insufficient to establish the national importance of the Petitioner's proposed endeavor”

  AAO decision text
• contract revenue · discounted

  “has not shown how the proposed endeavor's claimed employment projections have significant potential to employ U.S. workers”

  AAO decision text

Where this case turned

• 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
• Local, not national scope · p1 — impact confined to clients / a region

Notable

Petitioner relied heavily on multiple White House executive orders (on racial equity, COVID-19 relief, climate, opportunity zones, etc.) and the Small Business Jobs Act of 2010 to argue national importance; AAO rejected these as showing government interest in the broader policy area but not in the specific proposed endeavor. AAO adopted and affirmed the Director's prong-one analysis under Matter of Burbano before adding its own analysis.

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.

• Chen v. INS
• Flores v. Garland
• INA 203(b)(2)

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