Cite as 24 I&N Dec. 563 (BIA 2008) Interim Decision #3615 

Matter of EAC, INC., Applicant

Request for Accreditation 

New York, New York 

Decided July 3, 2008 

U.S. Department of Justice 

Executive Office for Immigration Review 

Board of Immigration Appeals 

(1) All accredited representatives on the staff of a recognized organization must have a 

broad knowledge of immigration law and procedure, even if the organization only intends 

to provide limited services through one or more partially accredited representatives. 

(2) In order to show that a proposed accredited representative has the broad knowledge and 

experience in immigration law and procedure required by 8 C.F.R. § 1292.2(d) (2008), 

a recognized organization should submit the individual’s resume, letters of 

recommendation, and evidence of immigration training completed, including detailed 

descriptions of the topics addressed. 

BEFORE: Board Panel: OSUNA, Acting Chairman; HOLMES and GRANT, Board 

Members. 

OSUNA, Acting Chairman: 

EAC, Inc. (Education & Assistance Corporation), an organization 

recognized by the Board of Immigration Appeals under 8 C.F.R. § 1292.2(a) 

(2008), submitted an application by letter requesting the accreditation of

Yvonne Buffa as its accredited representative under 8 C.F.R. § 1292.2(d).1 See 

Matter of EAC, Inc., 24 I&N Dec. 556 (BIA 2008). The application will be

approved. 

I. ACCREDITATION PROCESS 

By its very nature, effective representation of an alien, whether in matters 

before the Department of Homeland Security (“DHS”) or before the 

Immigration Judges and this Board, requires a broad knowledge of 

Although an application for recognition is submitted on Form EOIR-31 (Request for 

Recognition of a Non-Profit Religious, Charitable, Social Service, or Similar Organization), 

there is no specific form for an application for accreditation. 

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Cite as 24 I&N Dec. 563 (BIA 2008) Interim Decision #3615 

immigration law and procedure. This requirement exists to ensure that a duly

accredited representative is able to readily identify immigration issues of all

types, even in areas where no services are provided, and has the ability to

discern when it is in the best interests of the aliens served to refer those with 

more complex immigration issues elsewhere. A proposed representative’s

experience with immigration law need not be fully commensurate with his or 

her knowledge to be considered adequate.

Accreditation of a representative for practice solely before the DHS is

considered “partial accreditation,” while accreditation of a representative

before the DHS and the Board, which includes practice before the Immigration 

Judges, is considered “full accreditation.” See 8 C.F.R. § 1292.2(d). In 

addition to having the adequate knowledge, information, and experience in 

immigration law and procedure required for partial accreditation, 

representatives with full accreditation must possess skills essential for effective

litigation, including the ability to advocate a client’s position at a hearing

before an Immigration Judge by presenting documentary evidence and 

questioning witnesses, to present oral arguments before the Board, and to 

prepare motions and briefs for consideration by an Immigration Judge and/or 

this Board. All accredited representatives on the staff of a recognized

organization must have a broad knowledge of immigration law and procedure,

even if the organization only intends to provide limited services through one 

or more partially accredited representatives.

According to 8 C.F.R. § 1292.2(d), an organization recognized by the Board

may apply for accreditation of persons of good moral character as its 

representatives. An application for accreditation must fully set forth the nature

and extent of the proposed representative’s experience and knowledge of

immigration and nationality law and procedure and the category of 

accreditation sought, either full or partial. The request for accreditation should

include the proposed representative’s resume, letters of recommendation, and 

evidence of all immigration training that he or she has completed. Detailed 

descriptions of the topics addressed in recent immigration training should also

be provided to show that the individual has the knowledge and experience in

immigration law and procedure required for the services that he or she will 

provide through the organization. No individual may submit an application for 

accreditation on his or her own behalf. 

An application for accreditation should be filed directly with the Board,

along with proof of service of a copy of the application on the DHS. 8 C.F.R. 

§ 1292.2(d). Within 30 days, the DHS is required to submit a recommendation 

to the Board for approval or disapproval of the application and the reasons

therefor, or to request a specified period of time in which to conduct an 

investigation regarding the application. The organization has 30 days from the 

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date of service to file a response with the Board to any matters raised therein, 

with service of a copy of the response on the DHS.

The regulations also provide that the accreditation of a representative is

valid for a period of 3 years only. 8 C.F.R. § 1292.2(d). However, the 

accreditation remains valid pending Board consideration of an application

for renewal of accreditation if the application is filed at least 60 days before

the third anniversary of the date of the Board’s prior accreditation of the

representative. Accreditation terminates when the Board’s recognition of

the organization ends for any reason or when the representative’s employment 

or other connection with the organization ceases. The organization must 

promptly notify the Board of such changes. A representative may be 

accredited by more than one recognized organization, with multiple 

accreditations of a representative being most commonly sought by 

organizations that have more than one recognized branch office. In such 

instances, a separate request for accreditation from the recognized branch 

office must be submitted for any proposed representatives. 

II. ANALYSIS 

The applicant’s submission is a request for partial accreditation for 

Yvonne Buffa to practice solely before the DHS. A copy of the application

was served on the DHS, which has not responded to the request for a 

recommendation regarding the application. 

The evidence submitted in support of the application includes 

recommendations attesting to the good moral character of the proposed 

representative. She received an award from the Emigrant Savings Bank of 

New York for her commitment to the immigrant community. A resume 

indicates that she completed high school and has earned 55 credits at a 

community college. In addition, she has worked under the supervision of

immigration attorneys since 1986, primarily in the areas of naturalization and 

citizenship, and has completed applications for relief before the DHS. 

The proposed representative has also conducted various workshops to 

inform aliens of citizenship services, and she has prepared applicants for 

citizenship interviews. Moreover, she has completed several recent 

immigration law training sessions sponsored by the New York Immigration 

Coalition on a variety of topics covering a broad range of immigration law and 

procedure. She has also completed 10 sessions of training in various aspects 

of immigration law since 2005, including courses in the basics of immigration 

law and relief in immigration proceedings. Based on our review of the 

information submitted, we conclude that the application for partial

accreditation of Yvonne Buffa to represent individuals before the DHS should

be approved. 

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Cite as 24 I&N Dec. 563 (BIA 2008) Interim Decision #3615 

ORDER: The request for accreditation of the proposed representative for

practice before the Department of Homeland Security is approved. 

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