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USCIS · Request closures · Request IRW-076

New closing reason: "Missing Subject of Record Address"

This request asks for records about how USCIS added the closing reason "Missing Subject of Record Address" to FIRST, the system USCIS uses to track records requests, and began using it. It asks for items such as the change ticket, approvals, test results and instructions sent to staff.

Why it matters
A new reason for closing requests can change how many requests get closed. These records would show how the change was set up and put into use.
ClosedAppeal 4 business days to closure (4 calendar days)

Figures as of Oct 17, 2026. Check after Nov 16, 2026: if you are reading later than that, these figures may be out of date.

These figures are more than 30 days old. They may not reflect what has happened since Oct 17, 2026.

Timeline

  1. FiledSep 14, 2026
  2. ClosedSep 18, 2026
  3. Appeal filedSep 27, 2026 · Appeal IRW-076-AP · Pending decision

The closure and the appeal

Appeal IRW-076-AP · filed Sep 27, 2026 · Pending decision

Why USCIS closed the request

USCIS closed the request, claiming it did not follow its request rules (6 C.F.R. 5.3). The letter said the "subject of record's" date of birth was not provided, and that the signature was "unacceptable" for one of four listed reasons, without saying which one.

What the rules say

USCIS's identity rules apply to requests for records about a person: the requester (6 C.F.R. 5.3(a)(3)) or someone else (6 C.F.R. 5.3(a)(4)). The identity details and signature the letter asked for come from the rule for people seeking their own records (6 C.F.R. 5.21(e)). This request asked for agency records about how USCIS works, not records about a person, so those rules do not apply to it.

Why it was appealed

The appeal argues that the identity rules the letter relies on apply to requests for a person's own records (6 C.F.R. 5.3(a)(3) and 5.21(e)). This request names no person and asks only for agency records about a change to the FIRST system, so those rules do not apply and the closure should be reversed. No identity documents were attached, since none were required.

The closure and appeal sections summarize the letter and the appeal as filed. "What the rules say" is this site's explanation.

File this request too

Template T-55
Records documenting the addition and implementation of the closure reason code 'Missing Subject of Record Address' in FIRST on or about October 21, 2025, for the period September 1 through November 30, 2025: the change request or ticket and its attachments and comments; configuration specifications; approval records; test plans and results; deployment or release records showing the implementation date; and implementation instructions distributed to staff. Include records within these categories addressing implementation of the September 16, 2025 Verification of Identity guidance.
How to file it