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Hey John Rogers! I believe you have a lot of experience when it comes to this so I wanted to point you a question to you. What are the qualifications or prerequisites to get a September letter? Could potentially anyone get approved for this over a long period of time with regular approvals?
Homeland Security is deciding that the person is no longer or is not in need of a waiver. Some gun charges are easy September Letters. Its not something you "apply for" it CAN happen under certain circumstances when you apply for a waiver if you provide the proper information.
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