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Public Charge Rule Letter

Michael Dedmon | Policy Manager | The Financial Clinic


Samantha Deshommes

Chief, Regulatory Coordination Division

Office of Policy and Srategy

U.S. Citizenship and Immigration Services

Department of Homeland Security

20 Massachusetts Avenue NW

Washington, DC 20529-2140


10 December 2018

Re: DHS Docket No. USCIS-2010-0012 Inadmissibility on Public Charge Grounds


Dear Chief Samatha Deshommes,


First, I want to say that I appreciate this opportunity, on behalf of my organization, to comment on the Advanced Notice of Proposed Rulemaking (ANRP) regarding changes to the Inadmissibility on Public Charge Grounds. My name is Michael Dedmon, and I am the Policy Manager at the Financial Clinic, a New York City-based non-profit organization that fights financial insecurity  in low-to-moderate income communities through delivering direct services, capacity building for other nonprofits, and supporting systems level solutions and innovation. The Clinic and our partners are privileged to serve thousands of individuals from over 40 states who are themselves immigrants to the United States, and thousands more who count immigrants among their family, friends, and neighbors.

Many of these people have lived in our country before and been a vital part of our society for years, and with the proposed rule changes would face the prospect of being denied legal permanent residence or green card status as a result of their receiving support through programs like SNAP or Section 8 Housing Assistance. The suggestion that immigrant members of our communities are less deserving of obtaining permanent residence in the United States because they have received these supports is misguided, discriminatory, and cruel. In the strongest terms, I urge the Department of Homeland Security to withdraw the proposed “Inadmissibility on Public Charge Grounds” rule CIS No. 2499-10, DHS Docket No. USCIS-2010-0012.

The Financial Clinic has had the privilege of serving financially insecure low-and-moderate income communities in New York City since 2005. During that time we and our national partners have provided one-on-one financial coaching to over 48,000 individuals, many of them immigrants to this country, assisting them with identifying personal financial goals, creating a budget, accessing banking services or credit, and filing their taxes. Everyday our financial coaches see the challenges our customers face in building fulfilling and financially secure lives; challenges that are often only slightly, if meaningfully, mitigated on the support of public benefit programs like SNAP, Medicaid, and Section 8 housing assistance. Our experience serving our customers shows us that these programs give low-income families a necessary foundation on which to build financial capability, and rely on the support of federal and state programs for essential healthcare, nutrition, and shelter. Many of these beneficiaries are children or elderly. The proposed rule would force millions of individuals and families to choose between building the foundation for a better life, more financial security, and future success and gaining permanent legal residence. We should all see the cruelty in forcing our friends and neighbors to make this choice just because they are immigrants.

The nature of this false choice also makes it impossible to ignore its racial dimension. Because this rule targets elements of the family-based immigration system, it will certainly have a disproportionate impact on people of color by forcing them to forgo health and nutrition for themselves and their children. Taking into account resilience on such a wide set of public support programs for permanent residency, applications will necessarily reduce the diversity of immigrants entering and remaining in the United States, reshaping our country’s demographics for generations. The language used by the current administration lays bare the radicalized motivation of these proposed rule changes, and should cause all of us to be weary of their intent.

Immigrants do not take from this country, they enrich it. The proposed rule change is part of a larger agenda aimed at radically changing our legal immigration system with the goal of redefining who deserves to be an American and further stigmatizing reliance on any public benefit programs. The proposal sends the message to the world that the United States does not value our immigrant neighbors who work hard to build their lives here, relying on the same system of support that natural born citizens use every day. This message not only demeans members of our communities, but it will also certainly discourage others from immigrating and adding their talents to our society in fear that they may fall on hard times. The Financial Clinic firmly believes that when immigrants are harmed, we are all harmed. We cannot support this harmful rule change.

Thank you for your time and consideration.


Michael Dedmon, Policy Manager

The Financial Clinic




The Clinic’s Journey to Creating Lasting Change

By Michael Dedmon | Policy Manager

Since our founding in 2005, The Financial Clinic has put nearly $80 million back in the pockets of more than 48,000 customers. Over the years, we have grown from an organization focused on serving the working people of New York City to one that partners with over 460 organizations across 42 states to build the financial capability of low- to moderate-income Americans. Our capacity building work and our national financial security ecosystems give us the privilege of working with diverse communities from coast to coast, further informing our perspectives on the challenges that working people in this country face every day

As the scope of our work has expanded, our ambition to achieve our vision of a financially secure nation has grown as well. We are excited to announce that later this summer The Financial Clinic will – for the first time – release a national policy agenda that will guide our advocacy efforts in the coming years.

The Clinic will focus on a set of national policy priorities we believe best represent the opportunities to make a long-term impact in the lives of the people we serve, wherever we or our partners serve them. These efforts are continually guided by our core principles. The first is the belief that our customers are experts in their own lives and that – better than anyone – they know the challenges they face and the resources they need to address them. The organizations and communities we partner with hold vital knowledge and our goal is to combine this experience with data and powerful stories collected directly from our customers through our financial coaching platform, Change Machine, to ensure they remain at the center of our policy and advocacy efforts. Second, we know that fulfilling our vision of building a financially secure America requires addressing historic racial and gender inequities in economic opportunity created and sustained by our political institutions and public policies. Our advocacy will elevate the knowledge and capabilities of our partners and customers to support policies that remove systemic barriers, empowering minority communities to build lasting financial security.

The powerful combination of data we collect through Change Machine, the knowledge and expertise of our partners across the nation, and the lived experiences of our customers have reinforced our belief that many of the most significant barriers low- to moderate-income people face when attempting to build financial security are the result of systems and institutions that make it impossible to get ahead. Empowering individuals with the information and the skills they need is too often not enough; policies at the local, state, and national level can exacerbate the hardship families experience every day.

For this reason, the Clinic leverages our standing in the financial security field, our partnerships, and our unique customer data to develop and advocate for new policies that will create lasting change. In 2016, we partnered with the Citizens Committee for the Children of New York (CCCNY) and the New York Asset Development Coalition to pass the Refund529 bill. This legislation allows New York State tax filers to split their state refund and deposit a portion directly into a 529 college savings account. This new opportunity for tax time savings makes it easier for low- to moderate- income New Yorkers to invest in themselves and their families, access assets that build wealth, and give their children the necessary resources to attend and graduate college.

Our goal is to now apply the lessons learned from this successful campaign to a range of issue areas that will expand opportunity for working people across the country. We look forward to expanding this dimension of the Clinic’s work and joining with our customers and partners to advocate for policy changes that build a more financially secure America.