CLC Comment Opposing DHS and USCIS' Notice of Modification of System of Records

On December 1, 2025, CLC submitted a public comment opposing a Notice of Modified System of Records (SORN) published by the Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS). The modified SORN memorialized the overhaul of SAVE — a system originally created for the limited purpose of helping government agencies confirm the immigration status of applicants for public benefits — to facilitate voter verification, potentially for every American voter. CLC explained that the data on which SAVE relies contain significant inaccuracies that could result in the disenfranchisement of voters and that DHS has not implemented appropriate safeguards to protect Americans' sensitive data. CLC further explained that the federal government's aggressive and unprecedented use of SAVE for voter verification exceeds the executive branch's constitutional authority with respect to elections.