VZCZCXRO7260
RR RUEHBI RUEHCI RUEHGH RUEHNEH
DE RUEHBI #0486/01 3631528
ZNR UUUUU ZZH
R 291528Z DEC 09
FM AMCONSUL MUMBAI
TO RUEHC/SECSTATE WASHDC 7657
INFO RUEHNE/AMEMBASSY NEW DELHI 8867
RUEHCG/AMCONSUL CHENNAI 2175
RUEHNEH/AMCONSUL HYDERABAD 0062
RUEHCI/AMCONSUL KOLKATA 1962
RUEHGH/AMCONSUL SHANGHAI 0029
RUEHBI/AMCONSUL MUMBAI 2891

UNCLAS SECTION 01 OF 02 MUMBAI 000486 
 
SIPDIS 
 
"CA/FPP - PLEASE PASS TO DHS" 
 
E.O. 12958: N/A 
TAGS: CVIS OEXC KFRD IN
SUBJECT: I-20 FEVER: STUDENT VISA APPLICATIONS IN MUMBAI 
 
REF: A) 09 SHANGHAI 000293, B) 09 SHANGHAI 000361, C) 09 KOLKATA 000246 
 
¶1.  (SBU) SUMMARY.  Over the past year, Mumbai noted a marked 
rise in the number of lesser qualified student visa applicants, 
many of whom tended to apply to the same universities.  To 
explore this trend, Mumbai used entry/exit reports (ADIS) and 
student enrollment (SEVP) data to analyze the study patterns of 
800 randomly selected individuals, of whom 133 transferred 
within two years of their visa issuance. As most students expect 
to stay in the U.S. three to five years based on degree 
completion and the practical training that follows, assessment 
of university transfers with a focus on transfers to a lower 
level degree program was used as the main indicator for 
validation. The study found that multiple transfers were not 
uncommon and 40 percent of transfers were to a lower level 
degree program.  In a second random sample of applicants issued 
only for study at universities identified by adjudicators as 
attracting a higher number of unqualified applicants, the 
completion rate was lower, rate of terminations higher, and the 
number of transfers down was greater. END SUMMARY. 
¶2.  (SBU) BACKGROUND:  Of the 18,682 F1 applications for 
received in calendar year 2007, Mumbai's adjusted refusal rate 
for individuals was 21%.  An extraordinary number of repeat 
refusals inflates the refusal rate per application to 33%. 
Unqualified F1 visa applicants appear for third, fourth, and 
sometimes seventh interviews hoping for a different decision. 
Mumbai's refused student applicants are characterized by 
difficulty communicating in English (with or without anticipated 
English training on their I-20s), few or single university 
applications submitted, poor standardized test scores, financing 
by extended family dependant on agricultural income, and a 
rehearsed script of the reasons they selected the particular 
university. Many of these applicants state that they found the 
school on the internet, but when pressed during the interview 
acknowledge that they applied based on a local recruiting 
agent's presentation. 
METHODOLOGY AND RESULTS 
¶3. (SBU) To assess whether our F1 applicants maintain student 
status in the United States, Consulate General Mumbai conducted 
a validation study focusing on the F1 issuances of CY2007. Post 
began with a list of all F1 issuances from post for the calendar 
year 2007 from CCD AdHoc.  Students had two years to travel, 
enroll, transfer, drop out, or complete their programs.   Since 
the majority of our F1 applicants are pursuing master's degrees, 
completion in two years is not unrealistic.  From these 
issuances a random sample of 800 was drawn.  Given Shanghai's 
recent discovery of higher transfer rates from institutions that 
"attracted poorly qualified students" identified by Shanghai 
adjudicators (ref A), Post took a second random sampling of 800 
students from a targeted group of institutions.   Through 
CA/FPP, Post received ADIS results for these two samples of data. 
¶4.  (SBU) Adjudicators were asked to submit the names of 
educational institutions that consistently issue I-20s to our 
least qualified student applicants.  This list comprised twenty 
institutes, including the American Institute of Pharmaceutical 
Technology (AIPT), which received notice of intent to withdraw 
SEVIS issuing authority in December 2007, and the University of 
North Alabama (UNA), which issued more I-20 forms to Indian 
applicants than their total graduate student intake.   Mumbai 
alone saw 2070 applications annotated for UNA, though the 
University's website states UNA serves approximately 1000 
graduate business students.  Despite general concerns over 
educational institutions which appear to attract less qualified 
student visa applicants, 19% of issuances for Mumbai in 2007 
were annotated for attendance at one of these twenty 
universities of concern identified by adjudicators, highlighting 
Mumbai's commitment to adjudicating the applicant, not the 
school. 
¶5. (SBU) Of the 800 issuances in the general sample, the most 
recently reported status indicated 682 (84%) were in active 
status, 44 (6%) were terminated, 12 (2%) were cancelled, 13 (2%) 
were deactivated, and 42 (5%) had completed their programs.  By 
analyzing multiple records of active status, Mumbai was able to 
discern transfer narratives: 133 transfers were reported in 
SEVIS, of which 54 (40%) were transfers to a program with a 
lower educational code, for example Masters to Bachelors, 
Bachelors to Language Training, or Bachelors to Other 
Vocational.  Transfers down suggest that the applicant was 
unable to successfully complete the program to which he was 
admitted and cast doubt on the accuracy of admissions decisions 
by I-20 issuing authorities. 
¶6.   (SBU) Of the 800 cases from the schools of concern, 793 
were successfully matched to SEVIS records. Of these, 667 (84%) 
were in active status, 74 (9%) were terminated, 7 (1%) were 
cancelled, 16 (2%) were deactivated, and only 15 (2%) had 
completed their programs.   Not surprisingly, the targeted 
sample showed a lower rate of completion and higher rate of 
terminations.   Individuals issued visas to attend these schools 
 
MUMBAI 00000486  002 OF 002 
 
 
are reported to have transferred 146 times, of which 89 (60%) 
transfers were to lower coded programs. 
PRACTICAL TRAINING ALSO A CONCERN 
¶7.  (SBU) Several SEVIS records reviewed from among the "schools 
of concern" list provide anecdotal evidence that student's 
activities upon entering the U.S. appear to be inconsistent with 
the educational goals they had presented to the visa officer, 
and that I-20 issuing institutions appear to be exploiting the 
Practical Training exception in 9 FAM 41.61 N13.4. Examples 
include a student initially admitted to International Technical 
University in Sunnyvale, CA, who within a semester was granted 
CPT to work as a sales associate at 7-Eleven in Odenton, MD, 
followed immediately by CPT to at Motel 8 in Kalamazoo, MI.  In 
another case, SEVIS ID N0004673956 was granted CPT to work as a 
7-Eleven store manager on arrival to Silicon Valley University, 
another indication that certain institutions appear to be 
exploiting the Practical Training exception. 
¶8.  (SBU) A further trend, discovered when derivative F2s 
appeared for visa interviews to join their claimed full-time 
student spouses, was that certain F1 students were reportedly 
studying at the University of Northern Virginia in Manassas, but 
residing in Edison, New Jersey, a center of migration for 
Gujarati speakers from the Mumbai consular district.  For 
example, SEVIS ID N0004854481 has an "ACTIVE" SEVIS record at 
the University of Northern Virginia, which includes a comment 
stating the applicant is authorized to take a one year vacation, 
and concurrent "INITIAL" records at Essex Community College, NJ, 
and Our Planet Management, NY, which suggest he has submitted 
applications elsewhere. However, there are no indications that 
he is maintaining active status as a full time student. 
Similarly, SEVIS ID N0004297232 shows "ACTIVE" status at the 
University of Northern Virginia, with no mention of CPT 
authorization in New Jersey, but does show a "DEACTIVATED" 
record at New York's Bluedata International Institute without 
explanation in the previous month.  At the master's level, 
students are expected to maintain a course load of nine credit 
hours per term to maintain active status.  It is unclear how 
without performing off-site CPT work, this applicant managed to 
commute five and a half hours to attend classes.  COMMENT.  This 
pattern casts doubt on the accuracy of status reported by some 
institutions.  END COMMENT. 
RECOMMENDATIONS AND CONCLUSION 
¶9.  (SBU) COMMENT: In reviewing SEVIS records, Mumbai noted that 
very few records of termination or deactivated SEVIS status 
included comments.  Post recommends if possible that SEVP 
require a more detailed accounting of the reason SEVIS status 
becomes "CANCELLED," "TERMINATED," or "DEACTIVATED."   SEVP does 
not include information that would assist in determining 
students' whereabouts when they remain in country without 
maintaining status.  Moreover, the SEVIS Lookup feature on the 
CCD would be a stronger tool if it offered a "batch lookup" 
feature, making individual searches on a large sample of SEVIS 
IDs a less labor intensive process.  Much like CBP's powerful 
fraud prevention tool the Arrival Departure Information System 
(ADIS), a SEVIS search that can only be used for individual 
searches hampers posts' ability to perform targeted research on 
travel patterns of specific groups (ref B &C). 
¶10. (SBU) Mumbai will continue to adjudicate individual students 
not schools, but is concerned by the widespread over issuance of 
I-20s by universities that consistently see students transfer, 
become deactivated or cancelled.  A second trend of concern is 
universities that fail to update SEVIS status when students' 
residential addresses indicate they are not maintaining active 
status by registering for classes or working on authorized 
CPT/OPT . These trends ensure that Mumbai adjudicators will 
continue to assess the intent of student applicants to complete 
their stated degree program as a major factor in student visa 
adjudications.  END COMMENT. 
TYLERDA