Retention/Transfer/Porting of Priority Date between EB classes at I-485 stage
Hi Rajiv,
Thank you for this great service.
My main question is on the priority date retention specified in 8 CFR 204.5(e) and its interpretation.
I am Indian national. I have my I-485 currently pending, which was applied in Jul 2007 based on approved EB2 I-140 with priority date Feb 2007. Recently, another EB3 I-140 (with labor substitution), from the same employer and having PD Feb 2002, is approved. As per the above law, I retain the earlier priority date. Can we inform USCIS about this and have them adjudicate my I-485 with EB2 and earlier priority date (Feb 2002) since EB2 then becomes current with this new older priority date for India. My atty says USCIS won't entertain this request since both EB3 and EB2, with their respective I-140 PDs indicated above, are not current for India. According to him, at least one should be current when requesting this type of PD transfer. I disagreed with him and asked him to send the letter anyway to USCIS requesting them to use the earlier PD in my I-485 case. We agreed that this is not an interfiling request, which requires the new I-140 (to which one's I-485 is being transferred to) PD to be current. But he still doesn't feel that USCIS would entertain this request. I feel that they should. Otherwise, what is the point of PD retention when not being able to use against the better category (EB2 vs. EB3 in my case). Please correct me if I am wrong.
Another question is on the correct procedure to inform USCIS about this fact. Looking for this info online, some took the approach of amending EB2 priority date with old EB3 priority date while some simply sent a letter to USCIS with a copy of EB3 I-140 indicating the earlier PD and requesting them to use it for the beneficiary's A#. Some have indicated that the former approach to amend the EB2 PD is incorrect and amendment should only be used to correct any typographical errors etc.
Critical question:
When sending such a request letter to USCIS to use the earlier PD obtained from a different approved I-140 (EB3 in my case), does this result in any amendment to the underlying I-140 (EB2 in my case) on which one's I-485 is based? My understanding is that the priority date is tied to an A# (individual) at the stage of I-485 and we are simply requesting the agency to update it to an earlier date on the merit of another I-140 approval with older PD and adjudicate the corresponding I-485 accordingly. Am I correct?
Thank you very much.
psv007