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How to update your waiver after gender change

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We have an applicant that when they started the Waiver application their gender was male. They received their first Waiver as a male and then the second Waiver as a male. The second Waiver was issued May 30, 2014 and expires May 30, 2019.
In Jan 2017 they contacted us to let us know they had changed gender and name to female.
The Waiver is issued in her male name and gender (gender is not listed on Waiver but is on application). She contacted us as not sure if she can still use Waiver.
I contacted the Branch Chief at the ARO and explained the situation. I had inquired if simply providing to the ARO a copy of the Name Change Document and new Birth Certificate would suffice in getting an amended Waiver to reflect the new name. He said that ARO policy is that she would have to apply for an I-824 Replacement Waiver in order to make the changes and that simply providing a copy of the Name Change Document and new Birth Certificate is not acceptable.
He did say though that it is up to the discretion of the CBP officers at the border if they would allow her to use the Waiver with a copy of the Name Change Document and new Birth Certificate.


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