The CSC has offered some guidance when filing a case for an L-1B to L-1A conversion. First, the CSC advised that they do not consider these cases to be a “change of status”, and as such a $500 fraud fee should not be attached. They consider these cases to represent a change in a condition of employment but still within the L-1 status. Second, the CSC clarified that L-1B beneficiaries must have their L-1A extension petitions approved at least six months prior to the fifth year of the L-1B in order to benefit from the 7 year time limit given to the L-1A classification. If the case is not approved by this date, the L-1A petition will be granted up until the 5th year limit only. This seems to be at odds with USCIS prior guidance. However, if you have a case that applies to this situation you are encouraged to contact your HLG attorney for further guidance.