Submitted via regulations.gov
RE: CIS No. 2810-25; DHS Docket No. USCIS-2025-0004 Alien Registration Form and Evidence of Registration
The Canadian Snowbird Association (CSA) appreciates the opportunity to provide comments on the Interim Final Rule on “Alien Registration Form and Evidence of Registration” as released by the Department of Homeland Security (DHS).
Founded in 1992, the Canadian Snowbird Association (CSA) is a Canadian, not-for-profit advocacy organization dedicated to defending the interests of over one million Canadian travellers who travel south during the winter. The CSA works in partnership with government and business to educate and advocate on behalf of all travelling Canadians, helping to ensure access to safe and healthy travel.
The CSA strongly opposes the IFR. In this comment letter, we offer multiple considerations that we believe the Department of Homeland Security should take into account as the regulation is amended. There considerations include:
- The unnecessary burden the IFR poses on Canadian visitors to the U.S.
- The economic impact of the IFR on Canadian travel to the U.S.
I . The interim final rule creates an unnecessary burden on Canadian tourists to the United States
The IFR requires non-immigrant Canadian tourists and business travellers, who were not issued an electronic Form I-94 upon processing at a land port of entry, to submit a general registration form (G-325R) with United States Citizenship and Immigration Services (USCIS) if they will be physically present in the United States for thirty days or longer.
Canadian citizens generally do not require a visa to enter the United States directly from Canada for vacation purposes. Canadian visitors are generally granted a stay in the U.S. for up to six months less a day at the time of entry. For Canadian citizens entering the U.S., the I-94 process differs based on entry method: those arriving by air or sea typically receive an electronic Form I-94, while those entering by land generally do not receive an electronic Form I-94. Due to this difference in entry method, hundreds of thousands of Canadian travellers who enter the United States for extended stays of thirty days or longer, through a land port of entry, will be required to register with USCIS. A requirement we believe to be unnecessary.
With the extensive and ongoing information sharing between Canada and the United States, this additional requirement for Canadian visitors is redundant. In 2011, Canada and the United States committed to establishing a coordinated Entry/Exit information system as part of the Beyond the Border security agreement. This system permits the sharing of information, so that the record of an entry into one country can be used to establish an exit record from the other. Up until recent reforms, Canada and the U.S. only exchanged biographic entry information on third-country foreign nationals (not including Canadians or U.S. citizens), permanent residents of Canada (who are not U.S. citizens and lawful permanent residents of the U.S. (who are not Canadian citizens) at land ports of entry. However, since July 2019, Canada and the U.S. have been exchanging biographic entry data on all travellers who cross the land border.
This is in addition to the information-sharing agreement between both countries which gives each country access to the other’s criminal record and public safety information. United States law enforcement and border agencies have access to active records in the repository through the Canadian Police Information Centre (CPIC) system.
Furthermore, the IFR does not make clear whether members of the NEXUS trusted traveller program will be required to register with USCIS. As part of the process to become a NEXUS card holder, eligible Canadian citizens are required to undergo a personal interview and must submit fingerprints and/or photographic biometrics before acceptance into the program. As the U.S. government already possesses the biometric data of these travellers, it makes little sense to require them to register with USCIS for each extended trip they take to the United States.
II. The interim final rule will negatively impact travel and tourism to the United States
Applying the general registration requirement to Canadian citizens, as mandated under the IFR, will impact hundreds of thousands of travellers.
Implementing a registration requirement for Canadian visitors will negatively impact tourism to the United States. Canada is the largest international tourism market in the United States, with annual spending in excess of $20 billion USD. In Florida, Canadians represent almost 40 per cent of all foreign visitors to the state. Many local economies in the U.S. Sunbelt are reliant on Canadian visitors and the tourism dollars we bring. The U.S. Travel Association estimates that even a 10 per cent reduction in Canadian visitation could mean 2 million fewer visits, $2.1 billion in lost spending and 14,000 job losses.
Not since the COVID-19 pandemic has cross-border travel been this severely impacted. According to CBP data, the number of travellers entering the U.S. in a passenger vehicle decreased from 2,696,512 in February 2024 to 2,223,408 last month. The number of travellers driving over the U.S. land border is the lowest it’s been since April 2022. Policies, such as the registration requirement mandated under the IFR, contribute to this impact on cross-border travel. This will have a significant impact on the economies of cross-border and sunbelt communities.
We recommend exempting Canadian travellers who have not been issued an electronic Form I-94 from the general registration requirement. It is our position that Canadian citizens entering the United States at the land border, are ‘registered’ when they are inspected and admitted by U.S. Customs and Border Protection (CBP) officers at U.S. ports of entry. It is clear that executive order 14159 issued by President Trump was intended to be applied to unlawfully present individuals and not tourists temporarily visiting the United States. The form itself underscores that the executive order was not intended to target Canadian vacationers. The general registration form does not permit the user to enter a foreign address, in this case, a Canadian residential address.
The IFR is a step backward in bi-national relations and border security strategy between Canada and the United States. There is no reciprocal registration required of American citizens temporarily visiting Canada for vacation purposes, regardless of their authorized length of stay. The IFR establishes an unprecedented registration requirement on Canadian tourists who may be subject to civil and criminal penalties if they do not timely register with USCIS.
Our organization is appreciative of the opportunity to provide comments on the “Alien Registration Form and Evidence of Registration” IFR. If you require further information, please do not hesitate to contact Evan Rachkovsky, Director of Research and Communications at the Canadian Snowbird Association at evan.rachkovsky@snowbirds.org.
Sincerely,
Michael MacKenzie
Executive Director
Canadian Snowbird Association
