PA-2023-21: Statelessness Page: 3 Additional Considerations USCIS considered possible reliance and retroactivity interests with the issuance of this policy and applying it to pending applications, petitions, or requests. Nationality, or the fact that a noncitizen has no nationality, is relevant to all immigration benefits or actions, and has been a factor considered across a variety of applications, petitions, or requests. While individual directorates had some guidance on assessing statelessness, prior to the issuance of this policy, USCIS did not have agency-wide statelessness guidance. This policy utilizes existing agency expertise to foster greater consistency, accuracy, and efficiency. Accordingly, USCIS does not believe this policy adversely impacts reliance or retroactivity interests.