It has been reported that the USCIS has sent the proposed rule to OMB for a final review. If you have not read the proposed rule, a copy can be found here. The comment period only ended on Jan 2nd and it was expected that many attorneys, corporations, trade associations, potentially impacted individuals, and the customary deranged whack job that likes to rant about the H-1b worker who stole his job while he sat on his couch eating chips submitted comments. Our law firm submitted comments praising the idea of electronic registration but, expressing concern over the timing of this proposal and the proximity to this year’s lottery filings among other concerns including the information gathering, potential for fraud and abuse that appeared to be ignored and others. The quick action in sending the proposed rule to OMB less than 2 weeks after the comment period ended leads us to 3 conclusions: 1. the USCIS is trying to implement this rule in time for this year’s cap lottery 2. the rule as proposed was left largely intact and 3. the comments submitted were unread. Of course, our conclusions are pure conjecture so take them for what they are worth, possibly nothing. We will keep you updated as developments occur.