This sponsored column is by Law Office of James Montana PLLC. All questions about it should be directed to James Montana, Esq., Janice Chen, Esq., and Taryn Druge, Esq., practicing attorneys at The Law Office of James Montana PLLC, an immigration-focused law firm located in Falls Church, Virginia. The legal information given here is general in nature. If you want legal advice, contact us for an appointment.
Our immigration system is, in the main, funded by immigrants rather than tax dollars. Nearly 90% of immigration benefits applications – green card applications, work permit applications, the new asylum application, H-1B petitions, you name it – come with checks or money orders attached. Soon – on October 28, 2025 – that venerable system will come to an end. Inevitably, many people will miss the memo, and enormous numbers of applications will be returned to sender. The purpose of this sponsored post is to diminish that number slightly, and to offer a guide on how to make payments using the new system.
Method 1: ACH Transaction Using Form G-1650
The first method for paying via bank transfer, using Form G-1650. To do this, you have to hold a bank account – either checking or savings – at a U.S. bank. You have to provide the routing and account numbers for that bank account, and you have to sign a piece of paper authorizing the transfer of a specified sum of money. (If those elements sound familiar to you, that’s because they are the key characteristics of a check.) Use a computer to complete the form, print it, sign it, and attach it to your benefits application.
Interestingly, USCIS notes that you may need to contact your bank to permit USDHS to debit funds by ACH, and so it would be wise to speak to your bank to ensure that the Agency Location Codes – at this date, 7001010330, 7001010331, 7001010335, and 7001010390 – are authorized for debits.
Method 2: Credit Card Authorization Using Form G-1450
The second method is to authorize a credit card payment using Form G-1450. To do this, you have to have a working credit card, debit card, or prepaid debit card. Use a computer to complete the form, print it, sign it, and attach it to the benefits application.
USCIS currently notes that it only accepts credit card payments for payments to the USCIS Service Centers or USCIS Lockboxes. Currently, those two types of offices accept the overwhelming majority of payments, but some payments are made directly to the USCIS Field Offices – e.g., applications for emergency advance parole. It is unclear how those payments will be handled, but the current Policy Manual states that either a check or Form G-1450 will be acceptable.
Method 3: Request a Waiver Using Form G-1651
The third (and somewhat questionable) method is to attach a check or money order made out to “U.S. Department of Homeland Security” and request a waiver of the electronic payment requirement via Form G-1651. We can’t provide you with a copy of that form. USCIS promised to provide it by August 29, 2025, but they haven’t done so. USCIS says that these will be the acceptable categories for an exemption:
- Individuals who do not have access to banking services or electronic payment systems;
- Electronic disbursement would cause undue hardship, as contemplated in 31 CFR Part 208;
- National security or law enforcement related activities where non-EFT transactions are necessary or desirable; and
- Other circumstances as determined by the Secretary of the Treasury, as reflected in regulations or other guidance.
Whether these exemptions are real or not will depend on the bureaucratic apparatus. The biggest category by far is individuals who do not have access to banking services or electronic payment systems, which includes many immigrants. (Without a social security number, it is difficult to open a bank account.) USCIS may allow such applicants to pay via check or money order, attaching a Form G-1651; or USCIS may argue that the availability of prepaid debit cards over the counter means that everyone has effective access to electronic payment systems.
Our view is that this change is likely to make it harder for many people to apply for benefits on their own. Of course, as lawyers, we think it’s generally advisable to engage counsel to represent you before USCIS. We will have no trouble adapting to the new payment system. But this is just another little layer of complexity which will make an already complex system even more challenging for ordinary people to navigate – and, as such, we think it’s an unwelcome change.
