The regulation does not address what happens to the 11-digit admission number in electronic I-94 format. Often this information is required on USCIS forms and would be helpful to know whether the admission number would be continue to be used and whether it would be provided to the alien at the time of admission.
Secondly, the present system allows an alien to correct erroneous information on their paper I-94 by visiting any deferred inspection CBP office (by presenting paper I-94 and receiving a corrected one in its place). What procedures would be in place to correct the electronic I-94 form?
Thirdly, for aliens with electronic I-94 forms, how would their departures be recorded should they choose to depart by land to Canada or Mexico? What process, if any, do they have to follow at the land crossings?
Fourth, for those aliens whose status have been changed or stays extended by USCIS, the CBP paper I-94 provides a proof of admission and USCIS issued I-94 forms are evidence of subsequent status. How would the electronic I-94 forms work when such aliens apply for admission within 30 days of their departure (i.e. automatic revalidation)?
Comment Submitted by M.B.K.
This is comment on Rule
Definition of Form I-94 to Include Electronic Format
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