Comments to the Department of Homeland Security Opposing Notice of Proposed Rulemaking on Public Charge Determinations

December 10, 2018 — Comments

1. Credit reports and credit scores are inappropriate measures to determine the likelihood that
   an immigrant will become a public charge.
2. Immigrants are unlikely to have credit histories and credit scores.
3. Credit reports suffer from unacceptable rates of inaccuracy, especially for determining immigration status.
4. Use of credit scores will have a disparate impact on immigrants of color.
5. If USCIS makes public charge determinations using credit reports or credit scores, it must comply with the user duties under the FCRA.