We will not know the full extent of the Trump Administration’s immigration plans for another couple of months. However, we are predicting actions that may be likely based on the first Trump administration’s policies in 2017-2021 and the information available in the Heritage Foundation’s Project 2025 publication. Please join us as we preview actions the Trump Administration may take in 2025, the impact on businesses and employees, and actions we can take to prepare.

 

Issue #1: Wet Ink Signatures

 

What is the Policy?

 

During the Covid pandemic, USCIS started accepting copies of signatures on application forms, rather than requiring original wet ink signatures. This was done to facilitate the easier submission of applications during the pandemic when people could not meet in person or had trouble reaching offices. In July 2022 USCIS made this policy permanent through an announcement and change to the USCIS policy manual.

 

We predict USCIS will abandon this policy and require applications for immigration benefits to include wet ink signatures again.

 

Why Would the Trump Administration Implement this Policy?

 

The Trump administration will take this action simply because it can. Reverting to the requirement of wet ink signatures may be postulated as a security issue, but the reality is that re-establishing the policy will simply make immigration processes more complicated and more expensive. On the flip side, some in the agency may embrace the policy as a way to force applicants and their counsel to utilize the USCIS online submission process, when it is an available application choice.

 

The existing policy is merely a policy, not a regulation, and thus can be changed without any significant administrative burdens.

 

How to Prepare

 

Prior to the Covid pandemic, when USCIS previously required wet ink signatures, Meltzer Hellrung worked with clients to maintain files of signature pages to be used for application preparation. If the wet ink signature is reinstated we will work with clients to maintain multiple copies of signed forms again. Clients will ship signed copies of signature pages to our office and will maintain files of these. Meltzer Hellrung continues to maintain a physical office and sufficient space to maintain these files.