10/02/2026
Naturalization has become, in practical terms, harder than adjustment of status. Our attorneys recently spent more than four hours at the Santa Ana field office accompanying a client to a second N-400 interview, eighteen months after the first, where the questioning had centered on a minor issue from more than fifteen years earlier, outside the statutory good moral character period.
Two developments are worth practitioners' and applicants' attention. An applicant's complete record now surfaces at once and is escalated to a supervisor, with the result that the underlying grant of permanent residence is being re-examined during the citizenship interview. We have seen applicants informed that an officer erred on their original green card application and that the grant must therefore be revoked.
Separately, USCIS adopted a holistic good moral character standard on August 15, 2025, replacing a largely checklist-driven analysis with a totality of the circumstances assessment that weighs positive attributes such as educational attainment, employment history, community involvement and tax compliance. Whatever one makes of that as policy, it is now the standard an N-400 is measured against, and it rewards applicants who document those attributes affirmatively.
Practical guidance: anticipate administrative processing of three to six months or longer, prepare for a possible second interview, and assemble the good moral character record before filing rather than in response to an officer's question. It is also worth saying that many of the officers adjudicating these cases have been doing so for years and are working to get them right.
Featuring Attorney Joseph Tsang.
