USCIS Issues Nov. 4 Memo: Good Moral Character Review for Naturalization Now Weighs Support, Sponsorship and Benefits
U.S. Citizenship and Immigration Services (USCIS) issued Policy Memorandum PM-602-0201 on November 4, 2026, telling officers that the "good moral character" test for naturalization will now weigh an applicant's family support, sponsorship obligations and use of public benefits more directly. The memorandum applies to adjudications of Form N-400, the Application for Naturalization. USCIS said it will write new Policy Manual guidance and revise Form N-400 to collect more information about financial responsibilities, support of dependents and benefit use, without giving a date for either change.
Good moral character is a legal requirement for naturalization. An applicant generally must show good moral character during the five years before filing — three years for certain spouses of U.S. citizens — and continuing until the oath of allegiance, under a preponderance-of-the-evidence standard. USCIS said the review has never been limited to criminal history and may also cover tax compliance, financial obligations and other conduct; the new memorandum ties the test more directly to money: child support, sponsorship contracts and public benefits.
The memorandum lists six kinds of conduct that can lead an officer to find that an applicant lacks good moral character: willfully failing or refusing to support dependents, including minor children; fraud or deception in seeking, receiving or using public benefits; failing to meet obligations on an affidavit of support (Form I-864, I-864EZ or I-864A) while the obligation remains enforceable; failing to honor financial support commitments under Forms I-134 or I-134A while they remain in effect; unlawfully obtaining public benefits for oneself or helping dependents do so; and receiving means-tested public benefits for a reason that average members of the community would see as intentionally avoiding self-sufficiency. The memorandum also states that lawful receipt of public benefits is not itself a bar to naturalization and is not always a negative factor, and that officers must weigh the relevant factors case by case. A dependent's use of means-tested benefits may, depending on the circumstances, be evidence that the applicant failed to support that dependent.
The memorandum builds on an August 15, 2025 USCIS memorandum, effective August 17, 2025, that told officers to judge good moral character holistically under a "totality of circumstances" analysis, weighing past wrongdoing against rehabilitation and positive contributions, rather than checking a list of disqualifying acts. The November 4 memorandum adds a more detailed list of financial and welfare-related conduct to be weighed within that framework. The American Immigration Lawyers Association (AILA) logged the memorandum on November 4 as AILA Doc. No. 26110402.
USCIS said the revised Form N-400 will collect more detailed information from applicants about their financial support obligations and their history with public benefit programs. The memorandum does not set a separate effective date. In a separate step, USCIS guidance for Form I-485 filings on or after September 18, 2026 lets officers weigh a wider range of means-tested public benefits in the public-charge assessment for adjustment of status; the November 4 memorandum concerns the naturalization stage, a different procedure from the public-charge review at the green-card stage.
For green card holders preparing to naturalize, the practical effect will depend on how officers apply the standards in individual cases and on when the revised Form N-400 comes into use. USCIS said officers must decide each case individually, and that financial difficulties or lawful receipt of government assistance do not automatically disqualify a person from becoming a U.S. citizen.
Source: U.S. Citizenship and Immigration Services
Published by GSM · USA (original Chinese edition)
Photo: 图：美国公民及移民服务局总部（GSM 固定图库）。USCIS headquarters. (GSM asset library)
