MATTER OF A-A-F-M- INC.

APPEAL OF VERMONT SERVICE CENTER DECISION

Non-Precedent Decision of the Administrative Appeals Office

DATE: AUG. 30,2017

PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER

The Petitioner, an Asian supermarket, seeks to temporarily employ the Beneficiary as an "accountant" under the H-1 B nonimmigrant classification for specialty occupations. See Immigration and Nationality Act (the Act) section 101(a)(15)(H)(i)(b), 8 U.S.C. ~ 1101(a)(15)(H)(i)(b). The H-1B program allows a U.S. employer to temporarily employ a qualified foreign worker in a position that requires both (a) the theoretical and practical application of a body of highly specialized knowledge and (b) the attainment of a bachelor's or higher degree in the specific specialty (or its equivalent) as a minimum prerequisite for entry into the position.

The Director of the Vermont Service Center denied the petition, concluding that the record did not establish that the proffered position qualifies as a specialty occupation. The Petitioner later filed a motion to reopen that was dismissed by the Director.

On appeal, the Petitioner submits additional evidence and asserts that the Director erred in denying the petition.

Upon de novo review, we will dismiss the appeal.

I. LEGAL FRAMEWORK

Section 214(i)(l) of the Act, 8 U.S.C. § 1184(i)(l). defines the term ··specialty occupation" as an occupation that requires:

(A) theoretical and practical application of a body of highly specialized knowledge, and

(B) attainment of a bachelor's or higher degree in the specific specialty (or its equivalent) as a minimum for entry into the occupation in the United States.

The regulation at 8 C.F.R. § 214.2(h)(4)(ii) largely restates this statutory definition. but adds a non­exhaustive list of fields of endeavor. In addition, the regulations provide that the proffered position must meet one of the following criteria to qualify as a specialty occupation:

Matter (~f A-A-F-M- Inc.

(1) A baccalaureate or higher degree or its equivalent is normally the minimum requirement for entry into the particular position:

(2) The degree requirement is common to the industry in parallel positions among similar organizations or, in the alternative, an employer may show that its particular position is so complex or unique that it can be performed only by an individual with a degree;

(3) The employer normally requires a degree or its equivalent for the position: or

( 4) The nature of the specific duties [is] so specialized and complex that knowledge required to perform the duties is usually associated with the attainment of a baccalaureate or higher degree.

8 C.F.R. § 214.2(h)(4)(iii)(A). We have consistently interpreted the term .. degree"" to mean not just any baccalaureate or higher degree, but one in a specific specialty that is directly related to the proposed position. See Royal Siam Corp. v. Chertoff; 484 F.3d 139, 147 (1st Cir. 2007) (describing "a degree requirement in a specific specialty'' as ··one that relates directly to the duties and responsibilities of a particular position"): De{ensor v. Meissner. 201 F.3d 384. 387 (5th Cir. 2000).

II. PROFFERED POSITION

The Petitioner is an eight-employee company which operates an Asian supern1arket. It seeks to employ the Beneficiary as a full-time accountant, and submitted a certified labor condition application (LCA) 1

for a position located under the occupational category "Accountants and Auditors,"" corresponding to the Standard Occupational Classification code 13-2011, at a Level I wage rate.

In response to the Director's request for evidence (RFE), the Petitioner provided the following job duties for the proffered position (verbatim):

• Documenting the internal control documentation process. the implementation of GAAP accounting policies and procedures, budgets, forecasts and analyses: to•x, oftime on a weekly basis.

• Preparing and analyzing accounting records, financial statements and other financial transactional reports; 10% of time on a weekly basis.

1 The Petitioner is required to submit a certified LCA to demonstrate that it will pay an H-1 B worker the higher of either the prevailing wage for the occupational classification in the ··area of employment" or the actual wage paid by the employer to other employees with similar experience and qualifications who are performing the same services. See Matter (?fSimeio Solutions, LLC, 26 I&N Dec. 542, 545-546 (AAO 20 15).

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• Compiling and analyzing financial data to prepare budgets for the company. allocating current resources and estimating future financial needs: 10% of time on a weekly basis.

[The Beneficiary] will be engaged in all aspects of the Company's accounting management function. She will be responsible for preparing financial reports and analysis to the Company Management with an accurate. objective business cost model of the company and cost information that reflects the use of the Company" s resources. She will accurately value all operations through establishing. implementing and managing the accounting systems. She will also be maintaining detailed records and ensuring that all the corporate accounting records are in compliance with GAAP and advise the Management as to the forecasting. analysis and modification of the company's financial forecasting and budgeting ....

• Performing accompany accounting/financial activities and general ledger in timely basis, reconciling all balance sheet accounts on a monthly basis. 10% of time on a weekly basis.

• Reconciling company Bank statements and credit card statement m a timely manner; 5% of time on a weekly basis:

• Preparing and filing on time all sales and use tax, as well as other tax filings. preparing and tiling Form 941, 940 and VEC Returns on a timely manner: Preparing annual W-2 and W-3 forms; 10% of time on a weekly basis:

• Preparing financial statements including mcome statement and balance sheet: 10% of the time on a weekly basis.

• Performing accounting analysis, finance analysis. monthly and year end closings: 10% ofthe time on a weekly basis.

• Maintaining fixed asset sub-ledger, records depreciation. additions & disposals: 5% ofthe time on a weekly basis.

• Reviewing, reconciling and processing accounts payable including vendor invoices and owner expense reports to ensure accurate coding and timely payments; 5% of the time on a weekly basis.

• Preparing, and submitting all documents to court for ''Warrant m Debt-Bad Check" procedure. 5% of the time on a weekly basis.

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Matter of A-A-F-M- Inc.

• Assisting in preparing both short and long range financial plans and/or operating and capital budgets for the company's acquisition of other supermarkets plan in the near future; 5% of the time on a weekly basis.

• Providing financial advice and recommendation to the Management in order to efficiently distribute financial resources. 5% of the time on a weekly basis.

In response to the RFE, the Petitioner stated that the proffered position requires .. a Bachelor's degree in Accounting or Finance or Business Administration." On appeal, the Petitioner provides the opinion of a professor of accounting at asserting that the position requires a "bachelor's degree in Accountancy or Business Administration with a concentration in Finance."

III. ANALYSIS

We determine that the Petitioner has not demonstrated that the proffered positiOn qualities as a specialty occupation. Specifically, the record does not establish that the job duties reqUire an educational background, or its equivalent, commensurate with a specialty occupation.

As a preliminary matter, the Petitioner has not demonstrated that the Beneficiary will primarily perform the duties of an accountant. The duty description for the proffered position includes certain duties more consistent with a bookkeeping, accounting, or auditing clerk, such as reconciling company bank and credit card statements; and reviewing, reconciling, and processing accounts payable including vendor invoices and owner expense reports. See Bureau of Labor Statistics, U.S. Dep't of Labor, Occupational Outlook Handbook (Handbook), Bookkeeping, Accounting, and Auditing Clerks (2016-17 ed.).2

We acknowledge that the Petitioner has listed several duties consistent with an accountant position; however, it has not submitted sufficient evidence to corroborate that the company, an eight­employee Asian food market, requires a full-time accountant performing these services and that its operations would be sufficient to allow the Beneficiary to primarily perform the duties of an accountant rather than those duties more consistent with a bookkeeping, accounting. or auditing clerk. For instance, the Petitioner has not documented the job duties of its other employees, and demonstrated who else performs the company's routine bookkeeping, clerical, and other non-qualifying duties to relieve the Beneficiary from performing them.3

2 The Handbook indicates that bookkeeping, accounting, and auditing clerks may enter the occupation with some postsecondary education or just a high school diploma. !d. All of our references are to the 2016-2017 edition of the Handbook, which may be accessed at the Internet site http://www.bls.gov/ooh/. 3

While there is no provision in the law for specialty occupations permits the performance of non-qualifying duties, we will view the performance of duties that are incidental to the primary duties of the proffered position as acceptable when

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The Petitioner submitted the opinion of a professor of business management at the describing the Beneficiary's duties as including

assuring the conformity of accounts with "reporting and procedural standards:' "'documenting internal control procedures," "implementing GAAP ... policies and procedures for budgets. forecasts. financial analytics, and reporting," and preparing "annual operating budgets and perforn1ance variance reports." In addition, the duties provided in response to the RFE indicate that the Beneficiary will prepare ""short and long range financial plans and/or operating and capital budgets,'' and '"provide financial advice and recommendations . . . to management.., However, the Petitioner has provided insufficient supporting evidence to establish that these accounting duties will actually account for a majority of the Beneficiary's time. For instance, the record does not contain detailed information regarding the accounting standards, policies, or control procedures the company has implemented. Nor are there samples of financial analytics reports, forecasts, or variance reports the company has completed; or evidence of financial plans, budgets, or recommendations made to management by its accountants. This lack of supporting documentation is notable given the limited nature of the company's operations. the Beneficiary's continuous employment in this capacity since January 2014, and the Petitioner's claimed previous employment of an individual in this position from 2008 to 2014. It is the Petitioner's burden to establish eligibility for the immigration benefit sought. Section 291 of the Act, 8 U.S.C. § 1361; Matter ofSkirball Cultural Ctr., 25 I&N Dec. 799, 806 (AAO 2012).

Therefore, given the lack of evidence to support the duties of the proposed position, the Petitioner has not established the substantive nature of the work to be performed by the Beneficiary, which therefore precludes a finding that the proffered position satisfies any criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A), because it is the substantive nature of that work that detennines (1) the normal minimum educational requirement for entry into the particular position. which is the focus of criterion 1; (2) industry positions which are parallel to the pro tiered position and thus appropriate for review for a common degree requirement, under the first alternate prong of criterion 2; (3) the level of complexity or uniqueness of the proffered position, which is the focus of the second alternate prong of criterion 2: ( 4) the factual justification for a petitioner normally requiring a degree or its equivalent, when that is an issue under criterion 3; and (5) the degree of specialization and complexity ofthe specific duties. which is the focus of criterion 4.

Accordingly, as the Petitioner has not established that it has satisfied any of the criteria at 8 C.F.R. § 214.2(h)(4)(iii)(A), it cannot be found that the proffered position qualifies for classification as a specialty occupation. We will nevertheless perform a complete specialty occupation analysis under each ofthe four, alternative criteria at 8 C.F.R. §214.2(h)(4)(iii)(A), assuming arguendo that the proffered position is best classified under the "Accountants and Auditors" occupational category.4

they are unpredictable, intennittent, and of a minor nature. Anything beyond such incidental duties. however, e.g., predictable, recurring, and substantive job responsibilities, must be specialty occupation duties or the proffered position as a whole cannot be approved as a specialty occupation. 4 Although some aspects of the regulatory criteria may overlap, we will address each of the criteria individually.

Matter of A-A-F-M- Inc.

A. First Criterion

The criterion at 8 C.F.R. § 214.2(h)( 4)(iii)(A)(J) requires that a baccalaureate or higher degree in a specific specialty, or its equivalent, is normally the minimum requirement for entry into the particular position. We recognize the Handbook as an authoritative source on the duties and educational requirements of the wide variety of occupations that it addresses.

The Handbook does not indicate that an accounting or auditing position qualities as a specialty occupation. Specifically, the Handbook states that '"[m]ost accountant and auditor positions require at least a bachelor's degree in accounting or a related field." Bureau of Labor Statistics, U.S. Dep't of Labor, Occupational Outlook Handbook, Accountants and Auditors (20 16-17 ed. ). The Handbook reports further, however, that some with an associate's degree, as well as bookkeepers and accounting clerks, may "advance to accountant positions by showing their accounting skills on the job." Jd. A review of the Handbook does not indicate that an accountant or auditor position qualifies as a specialty occupation as it does not state a normal minimum requirement of a U.S. bachelor's or higher degree in a specific specialty, or its equivalent, for entry into the occupation.

Moreover, although the Occupational Information Network (O*NET) Summary Report for "Accountants" states that most of these occupations require a four-year bachelor· s degree, it also states that "not all" of them require such a degree. O*NET OnLine Summary Report for ""13-20 11.0 I - Accountants," http://www.onetonline.org/link/summary/13-20 11.01 (last visited Aug. 30, 2017). More importantly, O*NET does not reference any specific specialty. As such. even if the proffered position were determined to be an accountant position, it cannot be concluded based on the Handbook or O*NET that the position qualities as a specialty occupation normally requiring at least a bachelor's degree in accounting, or its equivalent.

The Petitioner has also designated the proffered positiOn at a Level I wage for accountants, indicating that the proffered position is a comparatively low, entry-level position relative to others within the occupation. 5 In accordance with the relevant Department of Labor explanatory information on wage levels, this wage rate indicates that the Beneficiary is only required to have a basic understanding of the occupation and that the Beneficiary is only expected to perform routine tasks requiring limited exercise of judgment: that she would be closely supervised: that her work would be closely monitored and reviewed for accuracy: and that she would receive specific instructions on required tasks and expected results. 6 Thus, even if the proffered position incorporates some duties of an accounting position, the Petitioner's designation of the position as a Level I position confirms that the position is more likely a junior or entry-level accounting position,

5 U.S. Dep't of Labor, Emp't & Training Admin .. Prevailing Wage Determination PoliL)· Guidance, Nonagric. Immigration Programs (rev. Nov. 2009), available at http://tlcdatacenter.com/download/NPWHC_Guidance_Revised_ 11_2009.pdf A prevailing wage determination starts with an entry level wage (Levell) and progresses to a higher wage level (up to Level IV) after considering the experience, education, and skill requirements of the Petitioner's job opportunity. !d. 6 /d.

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Matter qf A-A-F-M- Inc.

which according to the Handbook, would not require a bachelor's degree in the specific field of accounting or finance.

As we have noted, the Petitioner also submits the opinions and curricula vitae of and both of which opine that a position such as that presented in the instant manner

normally requires a bachelor's degree in accounting or business administration with a concentration in finance. We carefully evaluated the assertions of and but for the following reasons, determine that their opinions lend little probative value.

Both opinions indicate that their conclusions are based upon a review of the Beneficiary's duties listed herein, and further indicates that he '·reviewed corporate financial information·· in coming to his conclusion. However, neither opinion demonstrates in-depth knowledge of the Petitioner's specific business operations, and what duties the Beneficiary will perform in the context of its business.

For instance, with respect to the opinion of it is not clear what financial information he reviewed in reaching his conclusion and why this documentation would not have been identified and submitted for the record. Further, the opinion of indicates that his conclusion is largely based on the information on accountants included in the Handbook and O*NET. which as we have discussed, do not support a conclusion that a bachelor's degree in specific specialty is required for an entry level accountant. In addition, states that "the business has reached a level of complexity especially as the business expands where an accountant is needed," suggesting that an accountant was not previously required, a questionable statement given that the Beneficiary is asserted to have worked in this position since 2014 and another employee was stated to have acted in this capacity from 2008 to 2014. The Petitioner must resolve these inconsistencies in the record with independent, objective evidence pointing to where the truth lies. Matter ol Ho, 19 I&N Dec. 582. 591-92 (BIA 1988). Otherwise, the claimed experts do not reference, cite, or discuss any studies, surveys, industry publications, authoritative publications. or other sources of empirical information which they have consulted to complete their evaluations. .

The record also does not indicate whether the authors of the opinion letters were aware that as indicated by the Level I wage on the LCA, the Petitioner considered the proffered position to be an entry-level accountant position for a beginning employee who has only a basic understanding of the occupation. In other words, the Petitioner has not demonstrated that the asserted experts possessed the requisite information to adequately assess the nature of the position and appropriately determine parallel positions based upon the job duties and level of responsibilities.

As such, we find that the letters from and lend little probative value. Maller of Caron Int '!, 19 I&N Dec. 791, 795 (Comm 'r 1988) (providing that an adjudicator is not required to accept, or may give less weight to, an advisory opinion when it is ·'not in accord with other information or is in any way questionable.'').

The Petitioner has not established that the proffered position falls under an occupational category for which the Handbook, or another authoritative source, indicates that normally the minimum

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Matter of A-A-F-M- Inc.

requirement for entry is at least a bachelor's degree in a specific specialty, or its equivalent. The record lacks sufficient evidence to support a finding that the position, an entry-level accountant, would normally have such a minimum, specialty degree requirement or its equivalent.

The Petitioner has not satisfied the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(J).

B. Second Criterion

The second criterion presents two alternative prongs: "The degree requirement is common to the industry in parallel positions among similar organizations or, in the alternative. an employer may show that its particular position is so complex or unique that it can be performed only by an individual with a degree[.]" 8 C.F.R. § 214.2(h)(4)(iii)(A)(2) (emphasis added). The first prong concentrates upon the common industry practice, while the alternative prong narrows its focus to the Petitioner's specific position.

1 . First Prong

To satisfy this first prong of the second criterion, the Petitioner must establish that the "degree requirement" (i.e., a requirement of a bachelor's or higher degree in a specific specialty, or its equivalent) is common to the industry in parallel positions among similar organizations.

We generally consider the following sources of evidence to determine if there is such a common degree requirement: whether the Handbook reports that the industry requires a degree; whether the industry's professional association has made a degree a minimum entry requirement; and whether letters or affidavits from firms or individuals in the industry establish that such firms '·routinely employ and recruit only degreed individuals." See ,'Jhanti. Inc. v. Reno, 36 F. Supp. 2d 1151, 1165 (D. Minn. 1999) (quoting Hird/Blaker Corp. v. Sava. 712 F. Supp. 1095, 1102 (S.D.N.Y. 1989) (considering these "factors" to inform the commonality of a degree requirement)).

As previously discussed, the Petitioner has not established that its proffered position is one for which the Handbook, or another authoritative source, reports a requirement for at least a bachelor's degree in a specific specialty, or its equivalent. We incorporate by reference the previous discussion on the matter.

Beyond this, the opinion of states that ''it is common industry practice for companies that range in size from small businesses to international corporations to hire professional-level accounting personnel" and references four-year degree programs in finance and accounting. However, does not provide any support or probative sources for his suggestion that a specific four-year degree is commonly required for entry level accountant positions. Similarly,

makes assertions regarding "Parallel Accountant positions in organizations of similar size and business complexity in this competitive market sector:· but does not reference empirical sources to support his assertions.

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The Petitioner also submits several job announcements for accountant positions reflecting that a bachelor's degree in accounting or finance is required. However, we are unable to determine that these companies are similar to the Petitioner or that the submitted positions are parallel to the proffered position. For instance, the Petitioner provides little information on the size and revenue of these companies and how they compare to the Petitioner. Further, the Petitioner does not articulate or support how these companies are similar. This is particularly notable since the companies are not small retail businesses, but larger corporations operating in various industries, such as optics, pharmaceuticals, hotels, marketing, education, energy, insurance, and media. In addition. the Petitioner has not sufficiently established that the duties or the requirements for these positions are parallel to the proffered position.

In addition, the Petitioner submitted a letter from managing director of a 1 0-employee Asian food supermarket in New York, concluding that "[i]t is certainly customary and standard for similar situated organizations to require the minimum of a bachelor's degree in Accounting or a specific field of study related to an Accountant position." However. the writer does not explain what duties she associates with "accountants" such that we can determine the relevance of this letter to industry requirements for parallel positions. Further. does not indicate how she came to this conclusion, whether through the organizations own hiring practices or through other empirical sources. As such, we do not find that this letter provides much probative value in demonstrating bachelor's degree in accounting or a specific field of study related to an accountant position is required for similarly situated companies.

Otherwise, the record does not include any other probative evidence that a "degree requirement" (i.e., a requirement of a bachelor's or higher degree in a specific specialty, or its equivalent) is common to the industry in parallel positions among similar organizations. As such, the Petitioner has not satisfied the first alternative prong of8 C.F.R. § 214.2(h)(4)(iii)(A)(2).

2. Second Prong

We will next consider the second alternative prong of 8 C.F.R. § 214.2(h)(4)(iii)(A)(2), which is satisfied if the Petitioner shows that its particular position is so complex or unique that it can be performed only by an individual with at least a bachelor's degree in a specific specialty, or its equivalent.

As discussed, the Petitioner has designated the proffered position as a Level I position on the LCA, indicating that the Beneficiary will perform routine tasks that require limited exercise of judgment and that his work will be closely supervised, monitored, and reviewed for accuracy. See lJ .S. Dep't of Labor, Emp't & Training Admin., supra. Therefore, it does not appear that the position is one with complex or unique duties relative to other accountant positions requiring a significantly higher prevailing wage, as such a Level III (experienced) or Level IV (fully competent) wage level.

We note that while a few related courses may be beneficial in performing certain duties of the position, the Petitioner has not demonstrated how an established curriculum of such courses leading

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to a baccalaureate or higher degree in a specific specialty, or its equivalent, is required to perform the duties of the proffered position. Upon review, the record lacks sufficiently detailed information to distinguish the proffered position as more complex or unique.

The Petitioner claims that the Beneficiary is well-qualified for the position, and references his education and experience as evidence that the proffered position is a specialty occupation. However, the test to establish a position as a specialty occupation is not the education or experience of a proposed beneficiary, but whether the position itself requires at least a bachelor's degree in a specific specialty, or its equivalent. Here, the Petitioner did not sufficiently develop relative complexity or uniqueness as an aspect of the duties of the position, and it did not identify any tasks that are so complex or unique that only a specifically degreed individual could perform them. Thus, it cannot be concluded that the Petitioner has satisfied the second alternative prong of 8 C.F.R. § 214.2(h)(4)(iii)(A)(2).

C. Third Criterion

The third criterion of 8 C.F.R. § 214.2(h)(4)(iii)(A) entails an employer demonstrating that it normally requires a bachelor's degree in a specific specialty, or its equivalent, for the position.

The record must establish that a petitioner's stated degree requirement is not a matter of preference for high-caliber candidates but is necessitated instead by performance requirements of the position. See Defensor, 201 F.3d at 387-88. Were we limited solely to reviewing the Petitioner's claimed self-imposed requirements, any individual with a bachelor's degree could be brought to the United States to perform any occupation as long as the Petitioner created a token degree requirement. !d. Evidence provided in support of this criterion may include, but is not limited to. documentation regarding the Petitioner's past recruitment and hiring practices. as well as information regarding employees who previously held the position.

In support of this criterion, the Petitioner submits evidence that it employed another accountant from August 2008 to December 2013 holding a bachelor's degree in business administration with a major in finance. However, the evidence submitted leaves question as to whether this employee also primarily performed the duties of an accountant. The employee resume emphasizes duties inconsistent with an accountant position including ··daily accounts posting'' and "reconcil[ing] bank statement[s] and credit card statement[s].'' Therefore, the stated duties of this former employee suggest that his focus was largely on bookkeeping duties, much like the Beneficiary's. Further, the Petitioner provided IRS Forms W-2, Wage and Tax Statements, for this asserted accountant ret1ecting that he earned $26,200 in 2011, $31 ,600 in 2012, and $3 8.400 in 2013. These wages arc below the Level I prevailing wages for "Accountants and Auditors'' in 2011, 2012, and 2013. of $38,667 per year, $38,730 per year, and $39,624 per year, respectively, thus raising additional questions about the nature of his job duties. 7 Therefore, we do not find the submission of the

7 For more information about prevailing wages, see generally http://www.flcdatacenter.com/OESWizardStart.aspx (last visited Aug. 30, 20 17).

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educational credentials of one colleague sharing the Beneficim-y" s proposed job title convincing in establishing that the Petitioner normally requires a bachelor's degree in a specific specialty, or its equivalent, for the position.

Therefore, the Petitioner has not satisfied the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(3).

D. Fourth Criterion

The fourth criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A) requires a petitioner to establish that the nature of the specific duties is so specialized and complex that the knowledge required to perform them is usually associated with the attainment of a baccalaureate or higher degree in a specific specialty, or its equivalent.

However, we do not find that the submitted evidence sufficiently develops relative specialization and complexity as an aspect of the proffered position. We incorporate our earlier discussion and analysis regarding the duties of the proffered position, and the designation of the position in the LCA as a Level I position, and not as the higher Level Ill (referring to '·special skills or knowledge") or Level IV (referring to "complex or unusual problems'') wage levels.

The Petitioner has not demonstrated that its proffered position IS one with duties sufticiently specialized and complex to satisfy 8 C.F.R. § 214.2(h)( 4 )(iii)(A)( ./).

Because the Petitioner has not satisfied one of the criteria at 8 C.F.R. § 214.2(h)(4)(iii)(A). it has not demonstrated that the proffered position qualifies as a specialty occupation.

IV. CONCLUSION

The Petitioner has not established that the proffered position is a specialty occupation.

ORDER: The appeal is dismissed.

Cite as Matter (~f A-A-F-M- Inc., ID# 528553 (AAO Aug. 30, 2017)

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