I AM Immigration Clinics (Immigrants as Missions) Project Plan

Executive Summary

An estimated 50 ­ 80% of immigrants have unmet legal needs, a figure expected to rise with the proposed DACA/DAPA expansion. While these programs offer economic stability to immigrants and 1

their families, many immigrants cannot afford to hire a lawyer to help them navigate these complex cases. CIR will provide high quality, low cost legal assistance for immigrants by partnering with a multi­denominational coalition to establish I AM Immigration Clinics (Immigration as Missions), an affiliated network of certified clinics staffed with trained BIA accredited representatives and volunteers. We believe I AM Immigration Clinics is the first step to creating a multi­denominational movement among Christian churches to welcome the stranger. Through I AM Immigration Clinics the church will be able to better understand and respond to the emerging needs of our immigrant neighbors as well as receive the blessing that God is bringing to his church through immigrants.

As believers committed to the authority of God’s Word, the Church needs to respond, because the Bible commands us repeatedly to care for immigrants. We also need to face the reality that immigrants are joining our local churches in great numbers. If we avoid the realities of immigration we risk missing out on an incredible missional opportunity. While there are important economic and geopolitical reasons for why migration occurs, above them all is the hand of God in the movement of people for a particular purpose: “so that they would seek him and perhaps reach out for him and find him” (Acts 17:27).

To facilitate the church's response, I AM Immigration Clinics will host a series of one­day clinics across NC, before opening 5 permanent clinics in churches across central NC in 2016. Governance will occur at two levels: Local clinics will determine clinic hours and internal policies, maintain dedicated office space, and raise awareness of the clinic’s services in their supporting congregation and surrounding community. I AM Immigration Clinics will allow each clinic the freedom and modifications needed to fit their needs, building relationships between immigrants and church members and breaking down cultural stereotypes. Once the Board of I AM Immigration Clinics is established, it will have oversight and governance of all legal clinics in the partnership, including existing CIR clinic operations. The Board of I AM Immigration Clinics (with advisory input from CIR) will provide guidance for local clinic startups. Once the local clinics are established, the Board’s responsibilities will include technical assistance and accountability, communication/training, support services (including case management software and legal resources), and missional oversight. The Board will also assist local clinics with fundraising, staff management, and external public relations.

Each immigrant requesting aid will go through a thorough intake and screening process before being connected with a recognized BIA (Board of Immigration Appeals) accredited representative who will

1 Deferred Action for Childhood Arrivals and Deferred Action for Parental Accountability DACA (Deferred Action for Childhood Arrivals) was passed in 2012 and allows certain individuals who were brought to the US between the ages of 16 and 31 to obtain temporary work authorization and protection from deportation for a period of two years. In a 2014 executive action, President Obama expanded eligibility for DACA and created DAPA to provide the same relief for certain parents of U.S. citizens and lawful permanent residents. A U.S. District Court has issued a temporary stay against this executive action, halting implementation of the program until a court determines whether President Obama had the authority to create the DACA/DAPA expansion.

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handle their claim. A network of local attorneys will be available to handle more complicated cases as well as to provide technical assistance if needed.

Recruitment of lawyers, churches, and BIA representatives has already begun. During the second half of 2015, the I AM Immigration Clinics’ board will be formed, with the goal of opening the first five clinics in 2016.

Initial capital outlays for the I AM Immigration Clinics are $42,000 plus $47,700 for salaries and overhead. Ongoing operational costs for the Board (including Project Manager and a supervising attorney positions) are $115,680. While costs at the local clinic level will vary widely based on operational hours and congregational in­kind support, start up costs for a clinic operating 20 hours a week are estimated at $1,700 with ongoing operating costs of $1,773.17/mnt. This includes a salary for a paid BIA representative position at a suggested rate of $15/hr. These costs will be offset by program generated revenue, estimated to be $1,200/ mnt of clinic operations (based on historical data from CIR’s existing legal clinic).

We believe I AM Immigration Clinics provides the Christian church as a whole with a tremendous ministry opportunity with profound evangelical and social justice ramifications. This program will create deep, mutually beneficial relationships between churches and immigrant communities, and enable churches to minister to the hearts of those involved without being drawn into political debate. I AM Immigration Clinics offers local congregations the opportunity to provide well­organized, practical assistance to immigrants within their own community, putting feet to their faith and gaining a better understanding of their neighbors’ challenges, culture, and needs. And of course, the benefit to each immigrant who receives assistance from I AM Immigration Clinics cannot be overstated ­ it is truly life­changing. We invite you to partner with us in this endeavor, by providing funds for operational support, hosting a clinic at a church in your denomination, and actively promoting the program within your churches to encourage congregational support. Together we can meet the needs of our immigrant neighbors, help them achieve greater economic stability and better connect them with a supportive Christian community.

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TABLE OF CONTENTS

1. The NEED

2. Our response

3. I AM Immigration Clinics: Uniting the Faith Community to Meet Immigrants’ Legal

Needs

4. Governance

5. Geographic Focus

6. Timeline/Outcomes for 2015­2016

7. Plans for Expansion

8. Budget and Sustainability

9. Become a Part of the Solution

10. APPENDIX A: Background Information of BIA Clinics and Certification Process

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THE NEED

As a whole, immigrants are woefully in need of affordable legal services. A recent Harvard law review article estimated that 50 to 80% of immigrants have unmet legal needs. In 2012 the deferred action (DACA) plan brought a measure of economic stability to many immigrants by making it possible for them to obtain work eligibility. Many eligible immigrants still have not applied for this program. The expansion of DACA and DAPA (for parents of United States citizens) is expected to begin in fall of 2015, making approximately 155,000 more immigrants in NC eligible for relief. U­visas (visas available for victims of certain crimes who cooperate with law enforcement) make up another class of needs, as well as the unaccompanied minors (UAC) arriving from war­torn Central America, many of whom are eligible for Special Immigrant Juvenile Status (SIJS). Other immigration legal needs include claims for political asylum and family­based immigration visas, where an immigrant’s claim for lawful permanent residence status is based on his family relationship to a U.S. citizen.

In general, immigrants without legal representation are 5 times more likely to lose their cases than those with legal representation. The stakes are tremendously high ­ filing the wrong documents or missing a deadline can result in deportation. Without adequate counsel, these individuals are extremely vulnerable to unscrupulous businesses and employers who take advantage of their unfamiliarity with the law. An even greater threat comes from unauthorized “notarios” in the community who proclaim themselves to be experts in law, extort large sums of money from them, take their paperwork, misrepresent the law, or in some cases, do nothing to help them. Hiring an attorney, however, is tremendously expensive ­­ the average hourly rate for an immigration attorney is between $100 and $350 an hour.

For undocumented immigrants (about 5% of the state’s labor force), the situation is even more dire. Half of undocumented Latino immigrants rely on notarios. Lack of proper work authorization means they have little to no bargaining power with their employers, and many government benefit programs (including federally funded legal services) are closed to them. Improving legal access for immigrants would bring tremendous economic benefits, for individuals, families, and the community at large.

Demographers suggest that immigrants and their children from Latin America, Asia, and Africa will be the majority of American Christians within just a few decades. They bring a new vibrancy to our local churches, but—since the Church is one Body, with many members (1 Corinthians 12)—they have also entangled the Body of Christ in the morass of the U.S. immigration system. That means that we cannot give in to fear and avoid or avert our eyes from this issue.

OUR RESPONSE

CIR believes that these immediate legal needs can best be met with I AM Immigration Clinics (Immigrants as Missions), a multi­denominational network of Board of Immigration Appeals (BIA) recognized individuals and affiliate clinics, providing high quality, low cost legal assistance to our immigrant neighbors. (See Appendix A for background information on BIA clinics and certification) This collaboration has several key benefits that make it more desirable than establishing an independent clinic:

REPUTATION AND EXPERIENCE: CIR has experience operating as a legal clinic and has built established relationships of trust with immigrants and faith communities across NC.

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TIME: While it is possible for each clinic to establish their own nonprofit to form its own legal clinic, using CIR’s existing tax exempt status allows clinics to begin operation much earlier. Filing for federal tax exempt status is a lengthy and involved process ­ six months to a year. The need for legal access for immigrants will only worsen, particularly as DACA/DAPA takes effect. To make an impact, the Church needs to act sooner rather than later.

REDUCED OVERSIGHT/REPORTING REQUIREMENTS: Acting individually as their own

nonprofit, each clinic would have to establish its own policies, procedures, as well as comply with federal reporting requirements, which frequently require the services of an accountant and/or attorney. Operating under CIR’s tax exemption eliminates federal reporting requirements; a centralized governance provides oversight and allows local clinics to focus more on direct service.

COST: Affiliated clinics benefit from economies of scale

FUNDING: Collaborations are more easily funded than individual programs, particularly when

it comes to grants.

QUALITY: Affiliation takes advantage of the experience of all members, with shared best practices and the opportunity for ongoing training opportunities.

Initially, I AM Immigration Clinics will host a series of 5 one­day clinics across NC to advise immigrants of their rights under DACA/DAPA and help prepare applications. Five permanent clinics will be opened in 2016. The experience learned from these pilot clinics will be used to open an additional 10 clinics across NC in 2017.

We believe the establishment of these clinics is the first step to creating a movement among Christian churches that will better understand and respond to the emerging needs of our immigrant neighbors. The work done by the clinics cannot be underestimated, bringing life­changing stability to immigrant families and allowing them to fulfill their dreams. The benefits are not one­sided, however. Our desire is for churches to create a multi­faceted approach to meeting the specific needs of immigrant communities around them, building relationships of trust that result in meaningful change for all involved. We believe this will result in tremendous evangelism opportunities that are not forced, but the logical result of friendship and partnership. As the church steps up to address the issues before them, including poverty and racism, the entire community benefits.

Immigrants are often amongst the most receptive groups of people to the gospel; all around the world, God is at work through the movement of people to advance his kingdom. Scripture tells us that God has a design in the movement of people: that “from one man he made every nation of men, that they should inhabit the whole earth; and he determined the times set for them and the exact places where they should live” (Acts 17:26). While there are important economic and geopolitical reasons for why migration occurs, above them all is the hand of God in the movement of people for a particular purpose: “so that they would seek him and perhaps reach out for him and find him” (Acts 17:27).

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We will encourage and facilitate all involved with I AM Immigration Clinics to continue to expand their ministry to the immigrant community with the aid of CIR’s existing program focus and community engagement infrastructure.

I AM Immigration Clinics: UNITING THE FAITH COMMUNITY TO MEET IMMIGRANTS’ LEGAL NEEDS

I AM Immigration Clinics is designed to operate at two levels, with multiple local (point of service) sites, and as well as a centralized hub for shared resources, oversight, and accountability.

The primary role of the local clinic is to provide a location for client education and engagement ­ helping immigrants understand what the law is and how it applies to them. However, the missional nature of this project also means that clinics have a secondary role of educating their church congregations of the need for this service and why it is so critical to forming relationships that open the door for ministry opportunities with their immigrant neighbors. CIR has developed materials to help churches grapple Biblically with these issues, and also provides teaching, conferences and educational events to engage and inform the body about emergent immigrant issues.

The flowchart on the following page outlines the process for a typical immigrant seeking assistance at an I Am Immigration Clinic. A thorough screening process will ensure that the clinics take only the cases for which they are best suited, referring all others to partnering attorneys.

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Flowchart of A Typical Claim Handled by Local Clinics

In the event that additional information is requested in order to process the claim, the same BIA representative will continue to work on the case until disposition to ensure continuity and engender trust with the immigrant throughout the process. The amount of time needed to oversee a case from start to finish varies widely, from as little as 5 hours for a deferred action (DACA) claim, to more than 400 hours for cases involving u­visas.

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GOVERNANCE

Governance will be provided at two levels, at both the local level and with management oversight from the Board of Directors of I AM Immigration Clinics, with advisory input from CIR.

I AM Immigration Clinics Board of Directors’ oversight. This board will function as the centralized hub, providing oversight for all of the clinics, including the existing legal operations of CIR. While each will operate locally, the Board of Directors for I AM Immigration Clinics will be the glue that holds them together. This group will consist of representatives from each of the denominations involved in I AM Immigration Clinics, a member of CIR’s Board of Directors, and CIR Executive Director John Faison, who will act as the initial Project Manager for I AM Immigration Clinics.

The Board of I AM Immigration Clinics will assist local clinics as they become operational, including all requirements needed for BIA certification. Once the clinics are up and running, the Board’s responsibilities fall into five main areas:

1) Technical assistance and accountability. The process of BIA certification is complex; immigration law is even more complex. CIR’s past experience in both of these areas, as well as relationships with area immigration law experts, will allow the Board to ensure that all clinics will offer high quality assistance. The Board will oversee Project Manager in routine reviews of work done at each clinic for quality control. The Project Manager will track the favorable disposition rate for each clinic, as a metric of the quality of work being done. (The robust screening process should mean that only cases on which it is believed the immigrant can prevail will be accepted) Any denial of a claim will be thoroughly investigated to determine what should have been done differently. The Project Manager will also routinely survey clients, volunteers, and partnering attorneys to determine their level of satisfaction with the help offered, ease of access, management, quantity and timeliness of communication, and overall satisfaction. All surveys will be reviewed by the Board to discern not only the strengths of the programs, but areas of concern that need to be addressed.

Finally, the Board will proactively work with the clinics by requiring each BIA recognized individual to complete continuing education and make clinics aware of area trainings that would be beneficial.

2) Intra­clinic Communication. The beauty of establishing multiple clinics at one time is that it allows the clinics to communicate and learn from each other. We anticipate an annual meeting for the legal clinics to share best practices, offer support, and discuss common problems and issues.

3) Internal Support services. As the manager of several affiliates, the Board is able to capitalize on economies of scale, both in governance and operations. The Board will create standardized policies and operating agreements for local clinics. Bookkeeping will also be standardized, using CIR’s 501c3 designation to create a flow­through of tax­exempt donations to the local clinics. The Board will contract with CIR to purchase the case management and software system needed by all the clinics, and provide online access for legal research needs. Finally, the Board can assist with purchasing equipment and obtaining liability insurance.

4) External Support for the Program. I AM Immigration Clinics will only be successful with a clearly defined corresponding educational initiative that highlights the needs of immigrants in North Carolina and dispels misinformation and culture stereotypes. This education is best done from a central level,

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coordinating efforts with interested denominations and church congregations, utilizing media contacts, and the immigrant community itself to bring greater awareness of the need and help the Christian community become more engaged in immigrant issues. With this approach, fundraising becomes a natural extension of education, inviting individuals, denominations, and foundations to become financial partners with us.

5) Mission oversight. We believe very strongly in the role of the church in immigration reform, and believe that it is a biblical mandate to welcome our immigrant neighbors. We can begin to respond to this calling by offering legal, emotional, and spiritual assistance as immigrants reach out to us for it. However, we do not believe in forced evangelism and will actively discourage the churches we work with from proselytizing to the immigrants who seek their assistance. This does not mean that we are ashamed of our beliefs, as we will openly embrace opportunities that will allow us to openly and prayfully demonstrate our faith ­­ offering to pray with those who wish us to, and building long­term relationships, not just one­time conversations which will lead to opportunities for discipleship. Our services, however, will be available to all, regardless of religious belief. The Board of Directors, along with the Project Manager, will insure that this vision and spiritual integrity are carried out.

Governance at the local level: At the local level, each individual clinic will be responsible for determining the clinic hours of operation and internal policies unique to the clinics, as well as marketing the service to the surrounding community. At a minimum, clinics will need designated office space with computer and printer, accounting system, and insurance. Local clinics will have freedom to innovate and make modifications that better suit the plan to the needs of the surrounding immigrant community and their church. It is at this level that the impetus for a movement will be established ­­ in the building of relationships between immigrants and church members, breaking down cultural misunderstandings and stereotypes.

GEOGRAPHIC FOCUS

We will initially focus our efforts on the rural areas around Charlotte, Greensboro and Raleigh/Durham areas. These areas were chosen for the following reasons:

Area boasts highly concentrated immigrant populations (up to 13% of the counties, as opposed to 7.8% statewide)

Immigration Court for the region is located in Charlotte Thriving legal community ­ including all seven NC law schools, four of which have specific

immigration clinics that supervise upperclass students in handling immigration claims

However, our focus is not on establishing clinics in these metro areas directly, but around the outlying suburbs of these areas, where immigrants face the greatest barriers to legal access. We are positioning ourselves around the metro areas to be able to take advantage of the many resources available in them, but we plan to operate in areas where we can make the greatest impact as we work to build a network of legal immigrant support across central North Carolina.

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TIMELINE/OUTCOMES FOR 2015 ­ 2016

Critical dates and measurable outcomes for I AM Immigration Clinics for 2015­2016 are as follows. For a more detailed timeline, please see the attached file, Timeline)

I AM Immigration Clinics KEY DATES AND OUTCOMES FOR 2015­2016

2015/2016 Dates TASK/OUTCOME

March 2 ­ 6, 2015 Classroom training for future BIA representatives, in partnership with Immigrant Hope.

OUTCOME: 20 individuals community leaders, pastors demonstrate theknowledge needed for obtaining BIA recognition and begin the application process

April ­ May 2015 Project Plan Development:

Strategic Planning Sessions

OUTCOME: Finalized Project Plan (Business Plan) and creation of Initial budget

April ­ May 2015 Gain support of the legal community:

Recruitment of lawyers willing to assist with screening, oversight and referrals. (Each clinic will need access to an expert in criminal, civil/family and immigration law)

OUTCOME: 30 lawyers across central NC willing to provide volunteer assistance to I AM Immigration Clinics

April ­ September 2015

Individuals complete job shadowing requirements for BIA recognition

OUTCOME: 5 individuals complete the 40 hr job shadowing requirement needed for BIA certification by December

May ­ September 2015

Gain Denominational Approval and Congregation Buy­In

Create a project presentation to be presented before key decision makers ineach denomination to secure approval and committed funds.

OUTCOME: 5 Denominations committed to funding I AM Immigration Clinics for 3 years

Recruitment of churches as host sites for legal clinics

OUTCOME: 5 churches identified as legal clinic sites

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July ­

September 2015

Development of Governance Policies and I AM Immigration Clinics Board

OUTCOME: Creation of governance policies and organizational structure to support clinics, implementation plan and finalized annual budget;

OUTCOME: Board members identified and recruited

October 2015­

January 2016

I AM Immigration Clinics Board Implementation

OUTCOME: Board becomes functional, hiring staff, purchasing insurance, equipment, and case management system

OUTCOME:

October 2015 ­ January

2016

I AM Immigration Clinics hosts one day clinics held at host site locations forDACA/DAPA education and claim filing

OUTCOME: 5 informational meetings and 5 clinic work days, providingassistance to 200 immigrants across central NC, handling 200 DACA/DAPA claims

October 2015 I AM Immigration Clinics clinic sites file application for BIA recognition

OUTCOME: 5 sites submitting BIA application for certification

November 2015 ­

January 2016

Marketing: Identify target market areas and develop marketing plan

OUTCOME: Marketing Materials

December 2015 I AM Immigration Clinics affiliates receive BIA certification

January 2016­

March 2016

Development of Local Clinic Site Plans

OUTCOME: Local clinic sites finalized, internal board members are identified and recruited to then develop implementation plan and local clinic annual budget

April 2016­July 2016Implementation of Local Clinic Site Plans

OUTCOME: The board of each clinic convenes to develop local policiesand procedures, hire staff and purchase equipment and insurance needed for operations

July 2016 Local Clinics Become Operational

OUTCOME: 5 clinics operational in 2016, each capable of handling an estimated 200 cases by the end of 2016.

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By 2016, the 5 clinics will be handling at least 5 cases a month, resulting in 300 cases by end 2016. This figure is likely to increase drastically as the clinics become more familiar with the process, and could increase substantially more if immigration reform passes and is expedited. Each clinic will boast a favorable disposition rate of at least 88% by the end of 2016. Our thorough intake process and commitment to thoroughly evaluating any claim denial will enable us to maintain a high level of success in the clinics.

PLANS FOR EXPANSION:

The initial certification of 5 clinics to handle affirmative immigration claims is only the beginning of CIR’s plans. Additional expansion plans include:

Additional BIA certification of existing clinics, at the end of 2016, to allow clinics to personally represent immigrants in immigration court on defensive matters.

Training additional BIA representatives in Charlotte, NC in the fall of 2016 Opening 10 additional clinics in the Asheville/Hickory, Fayetteville, Wilmington, and Rocky

Mount areas by 2017.

BUDGET AND SUSTAINABILITY

A detailed budget for this project may be found in the attached spreadsheet. At a glance, start­up and operational costs may be broken down as follows:

I AM Immigration Clinics Projected Expenses:

START­UP COSTS ONGOING ANNUAL OPERATING COSTS

I AM Immigration Clinics Board of Directors/Hub Clinic*

CAPITAL INVESTMENT (Case management

software & Insurance)

$42,000 ­­­

PERSONNEL (½ time Project Manager)

(½ time Attorney) (Admin)

$47,700 $105,780

OPERATIONS $24,600 for one day clinics*

$9,900

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START­UP COSTS ONGOING ANNUAL OPERATING COSTS

Hypothetical Local Clinic Budget**

CAPITAL INVESTMENT (Technology/Office Supplies)

$1,000 ­ $3,000

Legal Case management $1200

PERSONNEL BIA representative

@20 hrs/wk $15/hr

$19,200 (to be offset by client fees)

OPERATIONS (insurance)

$600­1200

*Notes for I AM Immigration Clinics hub: The centralized hub of operations (consisting of the Board of I AM Immigration Clinics and CIR’s existing legal clinic will need to be established by the last quarter of 2015 to create the necessary policies and guidelines for the clinics to be up and running by 2016. This hub will share with CIR: a Project Manager (a half­time position) and an attorney (also at half­time, to oversee the centralized clinic and one day clinics during 2015) and accounting services. Salaries for 2015 are included in start­up costs and are not calculated in the operating budget, as additional staff will be needed immediately to lay the groundwork for the program.

**Notes for local clinic: At the local clinic level, initial startup costs will vary tremendously, based not only on the number of hours the clinic will decide to be operational, but also on the level of in­kind support received from the host church/denomination. We assume that the host site will be donating the overhead costs of office space, utilities, and telephone. While intake can be provided by volunteers, each clinic will need to fund a paid BIA representative, at a suggested cost of $15/hr.

Projected Income from I AM Immigration Clinics

Expenses from I AM Immigration Clinics will be offset by program generated revenue for clinic services, as each clinic will charge the nominal fee allowed by the BIA. For the one­day DACA/DAPA clinics in 2015, we anticipate revenue of $50,000, based on fees of $250 per case for 200 immigrants.

At the local clinic level, fees will also offset the costs of the program. Again, fees will vary for each clinic depending on operational hours. Historically, however, CIR’s existing legal clinic has generated approximately $14,400 a year in program revenue from legal fees, based on an an average of 5 clients a week. Using this figure, a satellite clinic launched by 4th quarter of 2015 would generate $10,000 in program revenue for 2016.

The potential therefore exists for clinics to be largely self­sustaining.

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Other Sources of Funding

In addition to program revenues, CIR has identified several other critical sources of funding, including denominational support, individual donations from host congregations, and foundational grants. Fundraising will be done at both the local level, with individual clinics seeking support from the surrounding community (including community foundations), as well as the centralized level (allowing CIR and the Board of Directors to cultivate statewide and national donors for the benefit of the entire program.

BECOME A PART OF THE SOLUTION

We are committed to providing immigrants in NC with increased access to high quality, low cost legal assistance through the establishment of multiple sites for our I AM Immigration Clinics. We hope that you will join us as we extend a welcoming hand of assistance to our immigrant neighbors.

Please prayerfully consider supporting the I AM Immigration Clinics initiative, by providing funds for operational support, hosting a clinic at a church in your denomination, and actively promoting the program within your churches to encourage congregational support. Together we can help our immigrant neighbors achieve greater economic stability and become better connected with a supportive Christian community.

If you would like to partner with us in these efforts, or have additional questions, please do not hesitate to contact CIR at jfaison@ciraleigh.org or (919) 322­0360.

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APPENDIX A: Background Information of BIA Clinics and Certification Process

As nonprofits have endeavored to meet immigrants’ legal needs, two models of clinics have emerged: attorney­staffed, and BIA accredited clinics. Attorney clinics, as the name implies, are staffed by attorneys, and typically cost at a minimum around $100K a year. For most nonprofits, this represents a tremendous financial burden. Recognizing this difficulty, the Board of Immigration Appeals allows a nonprofit to handle immigration claims (charging only nominal fees), provided the nonprofit can demonstrate rigorous training, job shadowing, and application procedures. BIA reps become recognized and non profits certified by:

Completing 40 hours of training and coursework in a classroom setting, as well as 40 to 60 hours of on­the job shadowing of immigration attorneys.

Detailing the supervision of staff and measures for quality control

Demonstrating adequate experience, as evidenced by resumes of the staff involved and letters of recommendation

Demonstrate sufficient access to legal resources, such as a law library.

Once an organization has been certified by the BIA, it can then staff the clinic with individual BIA reps. Each individual must be recognized by the BIA, a process that requires the site to document that individual’s experience and knowledge of immigration and naturalization law. These individuals are only permitted to provide legal assistance at the site of the clinic that filed the petition on their behalf.

Federal law establishes in 8 CFR 292.1 that a person entitled to representation may be represented by any of the following, subject to the limitations in 8 CFR 103.2(a)(3). 8 CFR 292.1(a)(4) Follows that certain accredited representatives who are representing and organization described 8 CFR 292.2 may represent such persons. Centro Internacional is an organization that conforms to 8 CFR 292.2 and I, John J Faison am accredited as described in 8 CFR 292.1(a)(4). Please see "Recognized Organizations and Accredited Representatives Roster" on the department of Justice web site, to confirm our authorization. http://www.justice.gov/eoir/ra/raroster_orgs_reps.htm Furthermore, according to the NC bar web site (https://www.ncbar.com/public/upl.asp) certain nonlawyers are allowed to offer limited legal services. See the language From NC Bar web page titled “Preventing Unlicensed Legal Practices” below: "By statute and regulation, some federal agencies permit lawyers licensed in any jurisdiction and nonlawyers to provide limited legal services before that agency. Those agencies include:

• Social Security Administration; • Internal Revenue Service; • Patent and Trademark Office; and • U.S. Citizenship and Immigration Services (USCIS)

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In 2014, a BIA ruling determined that a recognized organization need only apply for its representative’s accreditation at one location, and if approved, that representative may thereafter practice at any branch location of the organization that has been recognized by the Board of Immigration Appeals. Matter of EAC, Inc., 24 I&N Dec. 563 (BIA 2008), modified therefore clinics do not have to be independent sites, but can operate as an affiliate of a larger nonprofit. As a result of this ruling, a nonprofit can maintain multiple sites, creating a network of BIA recognized individuals who can work from multiple locations, allowing for economies of scope and specialized expertise to develop, raising the overall quality of the legal services rendered.

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