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The past few years have not been easy on the H-1B program.  Now, over the next few months, new regulations surrounding immigration to the United States will be introduced that will continue to impact H-1B beneficiaries, the employers that hire them, and the lawyers who represent them. 

Next month, December 2019, DHS announced they will propose regulation changes that, “Revise the definition of specialty occupation” and “revise the definition of employment and employer-employee relationship.”  They also announced changes surrounding wage level requirements.

These announcements come on the heels of recently declassified USCIS documents that show restriction of H-1B visas since 2017 with no basis in regulatory changes.

The bad news is, they may get their regulatory basis for rejecting and issuing RFEs for the H-1B petitions they have already been targeting.  The good news is, we already have a basis of understanding for how to work with these proposed regulations should they be passed, because we have been fighting these Denials and RFEs for years now, and we have gotten very good at it. 

Specialty Occupation Issues

In recent years, the exception has become the adjudicating factor when it comes to degree requirements for specialty occupations.  For example, a now-common RFE magnet job, Computer Programmer, usually requires a minimum of a US bachelor’s degree or higher to be hired to that position.  Sometimes employers will hire employees to this position with only an associate degree, so now petitions for these jobs constantly face specialty occupation issues.  Borderline occupations that sometimes do not have the bachelor’s degree minimum requirement will need added documentation as to why the job requires knowledge and skills associated with the attainment of a bachelor’s degree or higher, including a detailed job description and breakdown of the duties, tasks, and responsibilities of the job, and an expert opinion letter.

Employer-Employee Relationship Issues

Over the past few years, USCIS has been requiring H-1B workers that work on projects or at third party sites to have a complete itinerary of the work they will be performing for the entire duration of their H-1B visa.  This has especially impacted IT consulting firms.  If this is the situation, a complete timeline that lays out which projects the H-1B employee will be working on, where they will be working, who they will be working for, and how their work will be controlled and supervised is necessary.

Wage Level Issues

H-1B employees with low wage levels have run into trouble the past few years for issues largely related to specialty occupation issues.  USCIS often will wrongly associate a low wage level with an entry-level occupation.  This is not always the case.  The H-1B program was created largely in part to provide jobs for international students who graduate from US bachelor’s degree programs.  Since these graduates have the skills and knowledge needed for the job, but not necessarily the work experience, they will need a high level of supervision to start, which factors into their starting wage level.  If this is your situation, you must include a detailed breakdown of the factors that went into setting the wage level accompanied by an expert opinion letter that provides analysis and veracity to this decision.

Even if these new regulation proposals do not become law, there is no guarantee that USCIS will not simply continue to adjudicate H-1B petitions based on these guidelines.  If you, or if your employee or client faces one of these situations, it is important to be prepared.  Understand the added documentation your case will need, and make sure to provide an expert opinion letter from the RIGHT kind of expert whose credentials USCIS will accept.

For a free review of your case visit ccifree.com/. We will get back to you in 48 hours or less.

The Specialty Occupation RFE has become the scourge of H-1B hopefuls and their teams, and they are impacting occupations that had never been called into question before 2017. 

With the high rate of H-1B RFEs, it is important to understand what Specialty Occupation means, how the burden of proof as shifted in the past few years, and what USCIS is looking for as proof. 

There are four main categories that define a Specialty Occupation, and the H-1B job must fit in one of these categories:

1. The position must require a minimum of a US bachelor’s degree or higher or its equivalent.
2. It is an industry standard for this position to require a minimum of a US bachelor’s degree or higher.
3. It is an employer standard to require a minimum of a US bachelor’s degree or higher for this position.
4. The nature of this specific job is uniquely complex and specialized as to require whoever holds the position to have the skill and knowledge associated with having attained a minimum of a US bachelor’s degree or higher.

In general, it is advised to try to meet the requirements of at least two of these categories to avoid an RFE.

Since 2017, USCIS has started using the exception, instead of the norm, to justify rejecting H-1B petitions based on alleged specialty occupation issues.  The US Department of Labor Occupational Outlook Handbook is the main reference USCIS uses to discern if a job meets the first and second requirements.  In the past, jobs that typically required a US bachelor’s degree or higher, but not in all cases, would be approved.  Now, USCIS is adjudicating the exception as the rule.  That means if you, or your employee or client’s job is one of these “borderline” occupations, you need to aim for the third or fourth option as well to cover your bases.

If you, or if your employee or client’s job is specialized based on the third option, you need to provide documentation of past hiring practices and the ad for the job showing the minimum degree requirement.  It is also advised to address the fourth category and provide a detailed breakdown of the tasks and duties of the job showing how they require specialized skills and knowledge attained through having earned a US bachelor’s degree or higher.  If the job fits into the fourth category, you will need to provide this documentation as well.

For specialty occupation issues – whether you are filing an initial petition or refuting an RFE or Denial – it is advised to include an expert opinion letter from a professional in the industry of the H-1B job with extensive field experience.  The purpose of this letter is for the expert to lend their authority to your case, or to your employee or client’s case and explain why this particular job does require a minimum of a US bachelor’s degree or higher to effectively carry out its duties and responsibilities.  At TheDegreePeople.com we work with experts in every H-1B field, and it is the most effective strategy we have seen to prevent and successfully overturn H-1B specialty occupation RFEs.  For a free review of your case visit ccifree.com/. 

IT professionals have been hit the hardest by current USCIS policy changes to restrict the H-1B program without statutory basis.  In 2015, the Denial rate for H-1B petitions was just 6%.  This year, that number has reached 24% across industries, but IT companies have been hit the hardest.

Twelve IT companies that saw Denial rates of just 2-7% in 2015 now report Denial rates over 30%.  Prominent IT company Infosys saw a jump in H-1B Denials from 2% in 2015 to 45% in FY 2019.  Even major tech companies saw exponential increases in Denial rates from 2015%.  Amazon jumped from 1% to 6% and Intel jumped from 1% to 8%.

The National Foundation for American Policy reported, “Memos and policy changes […] make it more difficult for well-educated foreign nationals to work in America in science and engineering fields.”

This is bad news for US STEM industries because the United States does not have the highly skilled STEM workforce needed to meet the demand for the specialty occupations that make up the structure of these industries.  The effects of these restrictive policies are already being felt with US-based IT companies moving their hiring to overseas where they can be sure their workforce will be approved without Denials or multiple costly rounds of RFEs.  International companies are hesitant to expand their business to the United States for this same reason, and highly skilled foreign workers are taking their talents elsewhere.

If you or your employee or client is an IT professional petitioning for H-1B status, here is what you need to know about preventing and answering an RFE or Denial based on current USCIS approval trends:

1. Have a full work itinerary for the duration of the H-1B visa.

In recently declassified USCIS memos, it came to light that adjudicators have been instructed to require a full schedule of the H-1B employee’s workload for the entirety of the H-1B visa to meet the H-1B eligibility employer-employee relationship requirement.  While this is one of the questionable adjudicating factors that USCIS is getting pushback for, it is advisable to provide this information to optimize your chances of visa approval.

2. Include an expert opinion letter that discusses the wage level and the specialty occupation.

Over the past few years, occupations that had never before been called into question regarding their level of specialization are now regularly receiving RFEs for this issue.  Computer programmers and professionals making level one wages are particularly vulnerable.  This can be prevented or addressed in an RFE or Denial response with an expert opinion letter written by a professional in the industry of the H-1B job who has extensive field experience.  It’s on the petitioner and beneficiary to provide detailed documentation that clearly shows the specialized duties of the job, the ad for the job showing an advanced degree requirement, ads for the same position at similar companies that have the advanced degree requirement, a breakdown of factors that went into setting the wage level, and any other documentation you can provide that shows the job requires a highly specialized body of knowledge and skill to perform.  The opinion letter should cover both the job and the wage level.  At CCI TheDegreePeople.com we work with experts in all H-1B industries with the experience required for USCIS to accept their opinion letters.

3. If the beneficiary’s degree is from outside of the United States – ESPECIALLY if it is an Indian three-year bachelor’s degree – or if the degree is in a specialization different from the H-1B job, include a credential evaluation.

Any degree that was earned outside of the United States, is not an exact match for the H-1B job, or is incomplete, will need a credential evaluation that fills in any gaps between the degree the beneficiary has and the degree the beneficiary needs.  This is particularly true for beneficiaries with the Indian three-year bachelor’s degree as USCIS requires the missing fourth year to be accounted for.  This can be done with a work experience conversion wherein one year of college credit in the field of the job can be granted by a professor with the authority to grant college credit for work experience for three years of progressive work experience.  A detailed breakdown of course content and work experience conversions can be used to prove the beneficiary has the equivalency of the right degree in the right career to get that visa approved.  At CCI TheDegreePeople.com we work with difficult educational cases every year and we research and write each credential evaluation uniquely, with respect to the individual, the education, the H-1B job, and USICS approval trends, and we are very successful.

Current USCIS approval trends are unprecedentedly restrictive, and RFEs and Denials are getting overturned at record rates because USCIS is legally adjudicating them wrong.  However, taking steps to prevent an RFE or Denial is always worth the added effort on the front end, and knowing what you’re up against is most of the battle to successfully answer an RFE or Denial.

If you or your employee or client is facing an H-1B RFE or Denial, we can help.  We work with difficult cases every year and we get results.  For a free review of your case visit ccifree.com/.  We will get back to you in 48 hours or less.

Following the Trump Administration’s “Buy American and Hire American” policy, USCIS declassified documents show that approval standards for H-1B visas have changed without statutory basis.  This has led to a massive spike in RFEs and Denials for H-1B petitions – both for initial filings, and for H-1B extensions for cases that had previously been approved.

Executive director of the National Foundation for American Policy, Stuart Anderson says, “The denial rate for initial employment, primarily for new employees, has increased for nearly all leading companies.”

Although these tightened standards have impacted STEM industries the most, all industries have been impacted.  The National Foundation for American Policy told Forbes in August of 2019, “Denial rates for H-1B petitions have increased significantly, rising from 6% in FY 2015 to 33% through the second quarter of FY 2019 for new H-1B petitions for initial employment.”

Given these numbers, chances are you or your employee or client received an H-1B RFE or Denial for their FY 2020 petition filed back in April of 2019.  Don’t panic.  An RFE – and even a Denial – is not the end of the road.  While USCIS has been denying petitions at an unprecedented rate, appeals boards have been overturning adjudicators’ decisions to deny at an unprecedented rate as well.  USCIS is wrongly rejecting petitions and issuing RFEs. 

At CCI TheDegreePeople.com, we work with difficult H-1B cases every year, and we get excellent results.  That’s because we go back to the basics and identify H-1B eligibility requirements and USCIS approval trends, then see where the case in question is lacking in evidence, documentation, or equivalency evaluation.  If there are education issues, we address them with the right credential evaluation that takes the job, the degree, and progressive work experience into account.  If it’s a specialty occupation or wage level issue, we enlist the help of an expert in the industry with extensive work experience in the field to write an expert opinion letter.  We help our clients identify what documentation and evidence they need to provide in their response to get their desired results, and it works.

If you or your employee or client received an RFE or Denial, we can help.  For a free review of your case, visit ccifree.com/.  We will get back to you in 48 hours or less.

With the rising rate of H-1B denials being overturned in appeals and recently declassified USCIS memos that clearly showed restrictions to H-1B approval without legal basis, it is clear that USCIS is issuing RFEs for approvable petitions.

H-1B extension petitions for the same jobs, beneficiaries, and petitioners that have already been approved are getting RFEs and Denial in record rates.  At the same time, while the H-1B petition denial rose to 24% this year from just 10% in 2014, the Administrative Appeals office reversed nearly 15% of these Denials in 2018, up from just 3% from the fiscal year of 2014 to that of 2017.  USCIS is wrongly denying and issuing RFEs for cases that should – and sometimes previously have been – approved.

That means if you received an H-1B RFE this season, there is a very high chance that there is nothing wrong with the petition.  However, USCIS adjudicators are still the gatekeepers for this visa, and that means you still have to play their game.

At CCI TheDegreePeople.com, we work with difficult RFEs every year, and we have an exceptionally high rate of success because we have honed our strategy and always keep one eye on USCIS approval trends.  Here is what we recommend:  First, read over the RFE with your team.  Then, put it down and go back to the basic H-1B eligibility requirements.  Then, overlay current USCIS approval trends to see where your case needs strengthening.  If there are wage level or specialty occupation issues, this will require a detailed expert opinion letter included in your answer.  If there are education issues, this will require a detailed credential evaluation included in your answer.  This is how we conduct a review of your case to determine where more evidence and documentation, and clarification is needed, and it works.

In the words of former Congress member Bruce Morrison of Connecticut, denying and delaying approvable petitions is, “Attacking legal immigration.”  We need to fight back, and we can win, one case at a time.  For a free review of your case, visit ccifree.com/.  We will get back to you in 48 hours or less.

When USCIS finds a problem with your petition, or with your client or employee’s H-1B petition, more and more often they are finding something wrong with your response.  The second round of H-1B RFEs hit H-1B hopefuls harder than ever and like a ton of bricks last H-1B season, and this year is equally bad.

At CCI TheDegreePeople.com, we were able to answer the first round of RFEs with an above 90% success rate, preempting the second round of RFEs with our answer to the first. 

Here’s how:

When we review your case, or your employee or client’s case, we go back to the basics and see where evidence may be lacking in the areas of H-1B qualification.  We advise to address all these areas in the first response.  One common example of this is when a client comes to us with a double RFE for specialty occupation and wage level, but their education also raises questions.  Sometimes the degree is not an exact match for the job, or the degree was earned outside of the US.  Even if this is not on the initial RFE, it is likely to appear in the second round, especially if the justification for the position being a specialty occupation emphasizes the need for a specialized degree. 

We answer this RFE with an expert opinion letter from an expert in the field of the H-1B job who has extensive field experience.  This letter addresses both the specialty occupation issue, and the wage level issue.  Second, we write a credential evaluation that takes into consideration H-1B education requirements and the field of the H-1B job, to prove the beneficiary has the equivalency of the necessary degree in the exact field of the specialty occupation.  This may include emphasizing specific courses taken, converting years of progressive work experience in the field into years of college credit in the field of the H-1B job, and citing applicable USCIS precedent decisions.  This kind of approach works for a broad range of H-1B RFE situations.

Don’t wait for the second round of RFEs to fortify your case, or your employee or client’s case.  Visit ccifree.com/ for a free review of your case and consultation. 

At CCI TheDegreePeople.com we work with difficult H-1B RFEs every year, and over the past two years, we have seen a disproportionate number of specialty occupation RFEs for jobs that have never before been called into question.  This RFE and Denial trend was recently confirmed by the declassification of USCIS documents that fundamentally increased the burden of proof on the petitioner with no notice to the public.

These adjudication changes have no basis in changes to laws or regulations governing how H-1B visas can be approved or denied.  While immigration attorneys are taking USCIS to court over illegal denials, we are doing our part to get these RFEs overturned, and the way we do it is with an expert opinion letter.  The opinion of an expert in the field of the H-1B job as to whether or not the job meets specialty occupation requirements can successfully overturn an RFE, if these two crucial steps are followed:

1. Get the RIGHT expert.

USCIS accepts the opinion of some experts, but not others.  The RIGHT expert is a professional with years of experience working directly in the field of the H-1B visa.  If the expert has only instructed in the subject area but has limited or no field experience, USCIS will not accept that their credentials qualify them to write the opinion letter.

2. Provide the expert with as much documentation and detail as possible.

To prove the H-1B job is a specialty occupation, it must be clear that the job is so specialized and complex as to require the employee to hold a minimum of a bachelor’s degree or higher in the field of the specialization.  This can either be shown to be an industry standard for the position, or that this position for this employer is uniquely specialized.  To do this, you must provide a detailed job description outlining the specialized duties and responsibilities of the position, as well as proof of past hiring practices to show that the employer requires a bachelor-level degree in the field of the H-1B job as a minimum qualification to hire to the position in question.  You will also need to provide the ad for the job, ads for the same position for similar companies in the industry and be sure that the job description is an accurate match for the occupation and soc code selected on O*Net.  The more information you can provide to the expert, the better equipped they will be to write the opinion letter you need, or that your employee or client needs to get the RFE overturned.  As such, the more documentation you can provide USCIS to support the expert opinion letter the better your chance of success.

At CCI TheDegreePeople.com we work with experts in every H-1B field, and all our experts have the extensive field experience USCIS requires to give weight to their opinion letter.  We understand that when it comes to answering an RFE time is of the essence, and therefore we offer rush delivery options to suit your needs.  For a free review of your case, visit ccifree.com/.  We will get back to you in 48 hours or less.

The American Immigration Lawyers Association released USCIS documents following the settlement of a FOIA lawsuit that confirm their suspicions that USCIS has been limiting H-1B visas without legal precedent.

The USCIS documents made public are “H-1B RFE Standards” from March 23, 2017, and “H-1B AC21 Denial Standards, from July 17, 2017.  These changes followed the Trump administration’s policy of “Buy American, Hire American,” and intentionally restricts highly skilled foreign workers from US jobs.  These documents show USCIS adjudicators were instructed to deny visas in a way that breaks with legal precedents, overreaching Department of Labor regulations, and doing so without any regulatory or legal changes to base these sweeping changes in.

The two major points of impact are the limited scope of the employer-employee relationship, and specialty occupation.  These changes have already begun to hurt STEM industries in the United States.  The same companies that had over 50% of their initial H-1B filings denied in FY2019 only had a 4% or lower denial rate in FY2015.  This reflects the overall trend of denial and RFE rates skyrocketing without any changes to H-1B regulations.  In FY2015, the H-1B denial rate was 6% compared to 32% in the first quarter of FY2019 with over 60% of petitions receiving RFEs and only 60% of those getting approved.

Before the FY2017 memos, H-1B employees could be placed on non-productive status when there is lack of work provided by their employer, so long as the employee continues to be paid their prevailing wage salary.  This is based on a 1998 law stating that the employer-employee relationship persists even on non-productive status.  Now, to avoid Denial or RFE, employers must provide a complete itinerary of the H-1B employee’s work schedule for the duration of the visa. 

Before the FY2017 memos, jobs qualified as specialty occupations if the normal requirement for minimum educational standards for entry into the position is a US bachelor’s degree or higher or its equivalent. Now, for jobs like computer programmer and other common H-1B STEM jobs, if the US Department of Labor Occupational Outlook Handbook states that sometimes employers will hire employees to the position with less than the stated H-1B requirements, the position does not meet specialty occupation standards. In doing this, the interpretation has changed from the educational norm to the exception when adjudicating whether or not a position meets specialty occupation standards. 

Both of these changes put a much heavier burden of proof on H-1B petitioners.  These adjudication directions were changed without notification to the public, and without any changes to law or regulation.  Many have wondered if the RFEs they receive are even legal and the answer is no. 

Does that mean if you receive a Denial or RFE there is no hope for visa approval?  Absolutely not.  At CCI TheDegreePeople,com we work with difficult RFE and Denial cases every year.  While the past two years have seen a sharp increase in the rate of RFEs and Denials, the complexity and difficulty of answering these RFEs is no different from complex situations we have seen in the past.  For example, the Nightmare RFE has been around for years, calling virtually everything about a case into question and being virtually impossible to answer by its own instructions.  We have an over 90% success rate in answering these RFEs.  Over the past two years, we have an over 90% success rate in answering Specialty Occupation and Wage Level RFEs.  It just takes going back to the basic H-1B requirements and working from there with a creative approach and an understanding USCIS approval trends.

Declassification of these documents helps us understand what it really is USCIS needs to know about your case to approve the visa.  Don’t let sliding approval rates be discouraging, we can help.  Visit ccifree.com/ for a free review of your case.  We will get back to you in 48 hours or less.

The rate of H-1B petitions receiving an RFE instead of outright approval has skyrocketed to 60%.  That means if you, or your employee or client filed an H-1B petition back in April and made the lottery, they most likely received an RFE.  Of those 60% who received RFEs, just 60% of those RFEs are overturned and the visas are approved. 

These are not great odds, but there are steps you can take to ensure you, or your employee or client has the best chance of getting into that 60% of RFEs turned into visa approvals.

Here’s how:

First, go back to the basics.  USCIS requires that the H-1B worker holds a US bachelor’s degree or higher in the exact field of the H-1B job.  The H-1B job must require a minimum of a US bachelor’s degree or higher to perform.  This could either be an industry standard or a unique situation as evidenced by the high degree of complexity of this job and past employer hiring practices.  There must be an employer-employee relationship in which the employer can hire, fire, and otherwise control the work the H-1B employee performs, and the H-1B employee must make the prevailing wage for the job in that geographical location for companies of that size.

Second, sit down with your team and read the RFE carefully.  Try not to get too bogged down in the demands made by the verbiage of the RFE as many complex RFEs are virtually impossible to answer by their own instructions. 

Third, put the RFE down and determine which of the original H-1B eligibility requirements USCIS took issue with your case, or your employee or client’s case.  In which areas is your case, or your employee or client’s case lacking, and what evidence and documentation is needed to fill in the gaps?

Specialty occupation issues tend to go hand in hand with wage level issues.  Both can be addressed with an expert opinion letter written by an expert in the field of the H-1B job who has extensive field experience beyond just teaching in the field.  This letter is only as good as the evidence you provide the expert detailing the practical and theoretical application of a body of highly specialized knowledge and skill necessitated by the day-to-day duties and responsibilities of the job.  You will also have to provide evidence of industry or company hiring standard.  You will also have to detail what factors went into setting the wage level as it is.

Education issues can be addressed with the right credential evaluation.  Common education issues arise when an employee has a degree in a field other than the exact field of the H-1B job, a generalized degree, incomplete college, no college, or a degree earned in another country.  In all of these instances, the right credential evaluation that takes the job, education completed, and the H-1B beneficiary’s work experience into consideration, along with H-1B education regulations and USCIS approval trends.

At CCI TheDegreePeople.com, we work with difficult RFEs with a 90% and higher rate of success.  We work with experts in all H-1B fields and all of our credential evaluations are uniquely researched and written to address the situation.  Don’t take chances with answering an RFE.  Visit ccifree.com/ for a free review of your case, or your employee or client’s case.  We will get back to you in 48 hours or less.

Over the past three H-1B cap-subject seasons, we have seen an unprecedented rise in specialty occupation RFEs calling jobs into question that had never run into trouble before.  This trend is echoed across the entire H-1B visa program, with overall approval rates plummeting from over 80% in 2015 to around 60% for FY2019. 

USICS approval trends changing, however, is nothing new.  Before the rise of the specialty occupation RFE, education issues were the big change.  USCIS began issuing RFEs for petitions in which the employee held an advanced degree in a related field, requiring the employee have a degree in the exact field of the H-1B job.  This threw a wrench in the system but we learned how to successfully answer these RFEs with detailed credential evaluations and creative solutions. 

The biggest solution when addressing difficult RFEs of any kind are to go back to the basics and go from there.  It worked with education RFEs, and we have seen widespread success with it when facing specialty occupation RFEs. 

There are two main standards that must be met to qualify for H-1B status.  Although USCIS has raised the burden of proof to meet these standards, these two rules continue to be the guide to overturn an RFE.  The H-1B job must require a minimum of a US bachelor’s degree or higher to perform, and the H-1B employee must hold that degree or its equivalent.  In the recent past, the issue was to prove the employee had a degree in the exact field of the H-1B job, which often required a credential evaluation to fill in the gaps between the employee’s education and the H-1B job.  Now, we have to go several steps further in a similar way to prove that the H-1B job meets specialty occupation requirements.

In the past, jobs that typically required a minimum of a US bachelor’s degree or higher as an industry standard were making the cut.  Now they do not.  One major example of this is the job of computer programmer.  According to the US Department of Labor’s Occupational Outlook Handbook, sometimes employers will hire to this position with just an Associate’s degree.  In the past, the exception was not viewed as the norm, but now USCIS is adjudicating as it is.  To prove specialization, you and your team need to go further to prove why the job in question meets specialty occupation requirements despite the exceptions.

You will need to provide a detailed breakdown of the duties and responsibilities of the job that highlight the ways in which specialized skills and knowledge are applied theoretically and practically.  You will also need to show similar ads for the same job in similar companies in the industry to prove that a US bachelor’s degree or higher is the minimum requirement as a standard, as well as evidence of past employer hiring practices that show this minimum education requirement as a standard for this particular job. 

Along with this documentation, you will need to provide an expert opinion letter.  This expert must have extensive field experience as USCIS has rejected opinion letters from instructors and professors in the field who have not worked directly in the field beyond instructing it.  The expert will look over all of the documentation you have prepared for your RFE response and lend their opinion that this job does meet specialty occupation requirements.  At TheDegreePeople.com we have the right experts on hand in every field, and our experienced staff can help you work through the jargon of even the most difficult RFEs as we work with them every year.

USCIS approval trends change every year, and this challenge is no different.  Start by going back to the basic eligibility requirements and work diligently from there.

Remember, you only have 90 days from when you receive an RFE to respond to it.  Time is of the essence and waiting until the last minute will just hurt your chances of success.  For a free review of your case visit ccifree.com/.  We will get back to you in 48 hours or less.