The Petitioner, an insurance company executive with a background in mathematics, proposed to found and operate a life insurance company offering global life insurance coverage, U.S. market and real estate investment opportunities, currency diversification, and financial/retirement planning services.

Prong 1 — national importancenot established · dispositive

“These projections do not demonstrate that the Petitioner's company has significant potential to employ U.S. workers in an industry that the business plan states employs 6.3 million people.”

“These predicted profits do not establish that the Petitioner's company will have substantial positive economic effects in an industry the business plan states gamers foreign direct investment (FDI) of $763 billion.”

“Our assessment of national importance does not focus on the importance of an industry or issues affecting an industry in general, but instead "focuses on the specific endeavor that the foreign national proposes to undertake."”

“The record does not indicate that any of these products or services are unique, innovative or otherwise have national or global implications for the insurance industry.”

“Overall, the Petitioner's support letters attest to her past achievements, but do not establish the national importance of her proposed endeavor.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “These projections do not demonstrate that the Petitioner's company has significant potential to employ U.S. workers”

  AAO decision text
• recommendation letter · discounted

  “does not explain how the Petitioner's work would extend beyond her company's clients to impact the U.S. economy more broadly”

  AAO decision text
• other · discounted

  “None of these documents discuss the Petitioner's proposed endeavor.”

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

Notable

Petitioner argued SCOPS erred procedurally by issuing an RFE limited to prong 3 but then denying for failure on all three prongs; AAO rejected this, noting RFEs are discretionary and Petitioner had opportunity to submit further evidence on appeal but did not.

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

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