A New Memo with Immediate Effect
On August 22, 2025, U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0189, titled Resumption of Personal Investigations of Aliens Applying for Naturalization (INA 335(a)). The guidance took effect immediately upon issuance. It ends a decades-old practice of waiving neighborhood investigations and directs adjudicators to once again consider them in naturalization cases.
Under the new policy, applicants may be subject to in-person inquiries in the communities where they live and work. USCIS officers can interview neighbors, employers, or community members to verify residence and moral character. Although these investigations were once common, they had not been systematically conducted since the early 1990s. Importantly, even currently pending naturalization applications may experience additional delays if officers decide neighborhood checks are needed before final approval.
What the Memo Says
The memo rescinds the general waiver of neighborhood investigations and re-activates USCIS’s statutory authority. It emphasizes that:
- Decisions will be made case-by-case, at the discretion of officers.
- Applicants are encouraged, though not required, to proactively submit testimonial letters from neighbors, employers, or community members.
- Submitting such letters with the application may allow USCIS to determine that an investigation is unnecessary.
- Failure or refusal to provide supporting letters could trigger a neighborhood investigation or a formal Request for Evidence.
- The memo updates the USCIS Policy Manual but does not create enforceable rights in litigation.
In short, the new guidance restores tools that had been dormant for decades and signals a return to more intensive vetting in naturalization.
What the Law Actually Requires
The legal foundation for this policy comes from Section 335(a) of the Immigration and Nationality Act (INA), codified at 8 U.S.C. § 1446(a). The statute provides:
“Before a person may be naturalized, an employee of the Service, or of the United States designated by the Attorney General, shall conduct a personal investigation of the person applying for naturalization in the vicinity or vicinities in which such person has maintained his actual place of abode and in the vicinity or vicinities in which such person has been employed or has engaged in business or work for at least five years immediately preceding the filing of the application.”
This requirement dates back to the Immigration and Nationality Act of 1952. For decades, officers and investigators relied heavily on such checks, until they were largely phased out in 1991 in favor of FBI fingerprint and database screening. The August 22 memo does not change the law itself; it simply revives the agency’s practice of using this long-standing investigative authority.
What Issues the Checks Aim to Uncover
The purpose of neighborhood investigations is to corroborate whether the applicant truly meets the legal standards for naturalization. Officers may be looking for:
- Whether the applicant has genuinely resided at the stated address during the past five years.
- Whether the applicant is viewed as a person of good moral character by those in their community.
- Whether the applicant shows attachment to the principles of the U.S. Constitution and is well disposed to the good order and happiness of the United States.
- Whether there are concerns about unlawful conduct, misrepresentation, or lack of integration into the community.
It is important to note that USCIS already conducts background checks through the FBI for every naturalization applicant. Neighborhood investigations do not replace those checks; they are an additional step on top of them.
How USCIS May Conduct the Checks
Although the memo does not spell out procedures, past agency practice gives some clues. Similar to site visits conducted by the Fraud Detection and National Security (FDNS) unit for H-1B employers or for religious organizations sponsoring R-1 workers, USCIS officers may visit a neighborhood and speak with people nearby. They are likely to ask simple, informal questions designed to confirm whether the applicant is known in the community and whether the information on the application appears accurate.
Risks in Today’s Social Context
When Congress enacted INA 335(a) in 1952, communities were often closer-knit, and neighbors typically knew each other well. Today, in many American neighborhoods, residents have little or no interaction with one another. This creates new risks when officers rely on neighbor testimony:
- A neighbor who barely knows the applicant may give vague or unhelpful statements.
- Some neighbors may provide adverse information without basis, influenced by bias, prejudice, or personal disagreements.
- Even unfounded negative comments could lead USCIS to issue a Request for Evidence, prolonging the case and increasing the burden on the applicant.
- In diverse communities, this practice may also raise concerns about unequal treatment if prejudice or stereotyping influences neighbor responses.
For this reason, people considering naturalization should begin building connections in their communities well before applying. Developing friendships with neighbors, members of a religious congregation, or fellow participants in clubs and volunteer groups can make it easier to gather credible testimonial letters when the time comes.
What Kind of Letters Applicants May Need
Applicants should be prepared to gather letters that cover the five-year statutory period preceding their naturalization application. It is advisable to submit three to five credible letters from different sources. These may include:
- Neighbors, preferably from the neighborhoods where the applicant has lived during the last five years, who can confirm residence and responsible behavior.
- Employers who can vouch for steady work and reliability.
- Community members, such as religious leaders or volunteer coordinators, who can speak to civic engagement and character.
Each letter should include the writer’s name, contact information, relationship to the applicant, and specific observations of the applicant’s good moral character. Quality will matter more than quantity.
Applicants should also recognize that going back to past neighbors from earlier residences within the five-year period may be difficult, especially if there has been little contact since moving. This makes it important to maintain at least some relationships in every community where one resides, so that letters can be obtained when needed.
Why Legal Help May Now Be Necessary
For years, naturalization was considered one of the more straightforward immigration applications. Many lawful permanent residents filed on their own without legal representation. But the new memo raises the stakes.
Applicants must now think carefully about gathering testimonial evidence, choosing credible letter writers, and ensuring that the content of those letters addresses statutory requirements. Submitting weak or irrelevant evidence could result in Requests for Evidence or even trigger neighborhood investigations.
What was once a relatively routine filing may now require professional legal counsel. Guidance on which letters will carry the most weight, how many should be included, and how best to frame the evidence to meet INA 335(a)’s standards can make the difference between a smooth approval and a prolonged case.
Outlook
The reinstatement of neighborhood checks signals a new era of naturalization processing. USCIS frames it as restoring congressional intent, but the practical effect is to place additional burdens on applicants and their communities. With this policy now effective, applicants should plan ahead, build community relationships, gather testimonial evidence from the past five years, and consider legal advice to navigate the process successfully. Pending naturalization applications may also see slower adjudication as these additional steps are rolled out.
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