Personal Investigations Resume After Roughly 30 Years — Submitting Verification Letters in Advance Can Let You Skip the Investigation

USCIS has resumed neighborhood investigations in naturalization — the process by which a permanent resident acquires U.S. citizenship — review for the first time in roughly 30 years, and around the same time it raised the difficulty of the civics test and broadened the standard for evaluating good moral character. All three changes are already in effect or have been finalized through recent policy, and they apply immediately to applicants now preparing to file. On top of this, the comment period for the proposed naturalization fee increase closes in four days. With multiple changes overlapping right now, we lay out what applicants actually need to prepare before filing.

Neighborhood Investigations Return After Roughly 30 Years

"By policy memo dated August 22, 2025, USCIS ended the blanket waiver of the personal investigation requirement for naturalization applicants and directed that whether to conduct an investigation be determined on a case-by-case basis."

The law originally requires that naturalization applicants be investigated unless the Secretary of Homeland Security waives that requirement. USCIS had generally waived this requirement and relied mainly on fingerprint checks and FBI criminal record checks, but this memo ends that waiver. Not every applicant will be investigated, however. The officer reviews the file and decides on a case-by-case basis.

If selected for investigation, USCIS looks at the applicant's residence and place of employment for at least the 5 years before filing, verifying residency requirements, good moral character, attachment to the Constitution, and disposition toward the good order and happiness of the United States. From 1802 to 1981, applicants had to bring two witnesses to testify to their qualifications. One reason Congress eliminated that requirement was that character could instead be confirmed through investigation — yet investigations effectively stopped around 1991. This memo revives them after roughly 30 years.

The most practically important part lies elsewhere. USCIS may request verification letters written by neighbors, employers, colleagues, or business associates. The memo states that including such letters with the naturalization application (Form N-400) upfront helps USCIS decide whether to waive the investigation without a Request for Evidence (RFE), the process by which USCIS requests additional documents. Conversely, if an applicant does not cooperate in submitting such materials, it can lead to a neighborhood investigation and can also affect the demonstration of eligibility. Because this is a document you can prepare from the moment you file, it is better to have it ready before the interview is scheduled.

The Test Question Bank Has Grown, and the Passing Standard Has Risen

"Question bank: 100 questions → 128 questions. Questions asked: 10 → 20. Correct answers needed to pass: 6 → 12. Applies to naturalization applications filed on or after October 20, 2025."

Because 12 correct answers are now needed, broader preparation than before is required. The passing threshold itself remains 60%. The officer stops the test on the spot once 12 correct answers are confirmed, and also stops once 9 incorrect answers accumulate. Applicants age 65 or older who have held permanent residence for 20 years or more are unaffected by this revision. As before, they are asked 10 questions from a separate 20-question bank and need to answer 6 correctly. The English test exemption standards remain unchanged as well — over age 50 with 20 or more years of permanent residence, or over age 55 with 15 or more years of permanent residence, as of the filing date.

The civics test offers two opportunities — the initial test and a retest. Since the new question bank is broader than before, applicants should set aside ample study time before filing if they want to preserve their retest chance. Unless you qualify for the age-65 exception, you should prepare based on this expanded range. This revision applies to applications filed on or after October 20, 2025.

Character Review That Looks Beyond the Statutory Period

"The USCIS Policy Manual, in determining good moral character — a requirement examining whether the applicant has lived honestly during the statutory period — considers together the fulfillment of financial obligations such as tax payment, law-abiding conduct, community involvement, and the credibility of statements made."

The statutory review period is 5 years before filing for the general applicant, and 3 years for someone applying as the spouse of a U.S. citizen, and applicants must continue to meet this requirement up through the moment of naturalization. USCIS is not limited to looking only at conduct within that period. Even conduct predating the period can affect the determination if it does not show that current character has improved, or if it is relevant to current character. The Policy Manual directs that family relationships and background, the presence or absence of other criminal history, educational and employment history, and length of residence in the United States also be examined together, and these factors are used together by the officer in reaching an overall judgment on the individual case.

An applicant cannot be approved while on probation, parole, or a suspended sentence, but completing one of these without incident during the review period does not by itself disqualify the applicant. Expungement — a court order clearing a conviction record — does not, whether the conviction is domestic or foreign, erase the conviction itself for immigration purposes, and the officer can still require submission of records related to an expunged conviction.

In a separate policy alert last August, USCIS set out how it will treat unlawful voter registration, unlawful voting, and false claims of U.S. citizenship in naturalization review. It is itself unlawful for a noncitizen to vote in federal elections and most state elections, and this is separately subject to penalty under federal criminal provisions. If you have ever checked a box indicating U.S. citizenship on a voter registration form, you should work out the circumstances in advance.

Identity-Verification Procedures Must Be Complete Before the Interview

"Fingerprinting now applies to all naturalization applicants regardless of age. It was previously waived for applicants age 75 and older, but that waiver has been eliminated as electronic processing technology has improved."

The identity-verification procedure itself is not new; what has changed is that the pool of applicants subject to it has grown now that this waiver has been eliminated.

Fingerprints remain valid for 15 months from the date of FBI processing. Three identity checks — a fingerprint check, an FBI name check, and an interagency check that verifies records held by other federal agencies — must all be complete before the interview can be scheduled. Because the interview is scheduled only once all three are done, it is safest to act on a fingerprinting notice immediately and complete it by the assigned date.

In the same vein, on August 12, 2026, USCIS announced that it is temporarily reverting the procedure for civic organizations to assist with voter registration at naturalization oath ceremonies to the standard set by the June 28, 2017 guidance. This follows a ruling by the U.S. District Court for the District of Maryland on August 3, 2026, in a lawsuit brought by a civic organization against USCIS, which halted enforcement of the August 2025 policy; it applies pending the outcome of that litigation.

The Comment Deadline for the Fee Increase Proposal Is Four Days Away

"The notice of proposed rulemaking published in the Federal Register would raise the paper filing fee from $760 to $1,330, and the online filing fee from $710 to $1,280 — an increase of $570 in each case — and the comment period closes on August 24, 2026."

A notice of proposed rulemaking is the procedure by which DHS publishes a proposal for public comment before finalizing a new regulation. This notice was published in the Federal Register on June 23, and you can locate it there to submit a comment. The dollar amount is not the only thing changing. The proposal specifies eliminating the $380 reduced-fee option that applied to applicants at or below a certain income level, and also eliminating fee waiver eligibility for naturalization applications altogether. For applicants who have relied on a reduced fee or waiver to ease the burden until now, this provision matters more than the increase itself. As of August 20, when this is written, the final rule has not yet been published, so applications filed now remain subject to the current fees — $760 for paper filing and $710 for online filing.

When and in what form the final rule will be published may change depending on the outcome of the comment period. The mere fact that the comment deadline of August 24 is imminent does not by itself mean the increase is certain to be finalized, but since the $570 increase is not small, applicants who have been delaying filing should reconsider their timeline at this point.

Closing

If you are preparing to apply for citizenship, you should set your priorities. Before filing, have verification letters from neighbors and employers ready in advance. Check whether your planned filing date falls under the October 20, 2025 standard, and prepare for the civics test using the 128-question bank. Also check whether you qualify for an age-based exception, such as being 65 or older with 20 or more years of permanent residence. If you have a history — such as tax filings or a criminal record — that could affect the character determination, address it first. If you receive a fingerprinting notice, act on it immediately according to schedule so the interview is not delayed. Since whether the fee increase will take effect is not yet finalized, there is no reason to rush your filing date while your documents are not yet ready. If you plan to file using a reduced fee or a fee waiver, however, you should factor into your schedule that this option could be eliminated along with the increase. And if there are circumstances that could affect the character determination, you should have an immigration attorney review your application content and supporting documents before filing. This is a period when several changes have converged at once. The order of operations is to line up your documents piece by piece before setting a filing date.

Disclaimer: This column is provided for general informational purposes only and does not constitute legal advice for any specific case. For matters concerning your individual immigration situation, please consult an immigration attorney.

Law Office of Attorney Jin D. Cho

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