does not confer lawful status—and U.S. immigration authorities generally will not take action against individuals who have DA. The individual may also be eligible to receive social security benefits to which she is entitled. Practice Point In counseling a stateless client, consider that DA is not a solution to statelessness, and it presents several challenges: It does not confer a specific permanent legal status in the United States and does not open a pathway to citizenship; the DA grant is only for a limited time, after which the individual must seek a new grant of DA;117 and it can be subject to review and termination at any time, with no guidelines on how frequent or how invasive this review can be. Moreover, there is no requirement that an individual be informed as to why she is being reviewed or why her deferred action grant is being terminated. B. Requesting Deferred Action 1. Preparing the DA Request There is no specific form to be filed for a DA request. Rather, a written request—usually in the form of a letter or a short brief—is the preferred means of pursuing this form of relief. This letter may be sent to a local ICE Field Office or local USCIS office. The following provides a non-exhaustive list of guidance in preparing a request for deferred action on behalf of a stateless individual: ! Bio-data: List the individual’s full name, alien number, and the place and date of birth.118 ! Information on statelessness: Provide an overview of why the individual is stateless (including legal arguments) and what it means to be stateless in the United States, including that the individual is not stateless due to his or her own actions or inactions. Explain that it is not possible for this individual to be removed from the United States. ! Immigration history: Summarize how the individual entered the United States and the individual’s procedural history and current status. Explain if the individual has or does not have another form of relief. In the case of stateless persons with final removal orders, the request should address any reporting requirements and summarize the individual’s history of compliance with the reporting requirements. If the person is on OSUP, this should emphasize the cost of reporting, while if the person has no work authorization, the letter should emphasize the individual’s inability to work and pay taxes. This section can emphasize that the individual does not have any other options available and that as a stateless person, she remains in this limbo indefinitely. ! Connection to other States: Where relevant, emphasize that by virtue of having no nationality, a stateless person has no formal ties to another State. ! Life in the United States: The letter should emphasize any ties to the community, including marriage, U.S. citizen or lawful permanent resident family, length of stay in the United States NICOLE COMSTOCK, LINNEA IGNATIUS, SHOBA SIVAPRASAD WADHIA, ANNA GALLAGHER, & DENYSE SABAGH, PRIVATE BILLS AND DEFERRED ACTION TOOLKIT 5 (2011), available at https://www.informedimmigrant.com/wpcontent/uploads/2017/03/PBDA_Toolkit.pdf. 118 ICE Tool Kit for Prosecutors, supra note 112. 117 25