In the United States, the decision to admit an alien student to study, and to subsequently work in a government-subsidized job, is not made by the government; the decision, for all practical purposes, is made by the college or university involved.
Though that may be viewed as a remarkable way to run the system, it is not a new development.
We at CIS have recently learned just how low the standards are for selecting the institutions of higher learning that are granted the right to make these decisions; it came about by accident.
Our interest was in a passage in a criminal complaint about an exploitative mega church with its headquarters in the Philippines and large branches in the United States. According to the document, filed in the Central District of California federal court, the church would lure nonimmigrants from the old country to the United States, seize their passports, force them into the streets begging on behalf of a non-existent children's charity, and then funnel the funds raised off to the Philippines where they supported the church's leader's whims, such as both a private helicopter and a private jet.
The passage of interest in the complaint related to one of the ways that the church, "Kingdom of Jesus Christ, The Name Above Every Name" (KOJC), used to keep these victims in what appeared to be legal status; the church enrolled them as F-1 students in one or more universities, offering a week's worth of classes in a single day; meaning that they could keep on "fund-raising" the other six days a week.
This practice made the usual visa mill operation look bland in the comparison, as the students in those schools are not enslaved, but are typically using the school to meet their own ends.
The complaint mentioned the universities, but not by name. We poked around a few days later and got the names. It turned out that there are four of them, all previously unknown to us.
If KOJC is a whale of a church (or "church"), then its collaborators are minnows — minnows engaged in a criminal activity, but still minnows; all of them deserve to be indicted if the information in the criminal complaint is correct and pertains to all of them.
The four schools, in order of apparent descending size are:
- California University of Business and Technology, Hacienda Heights, Calif.;
- Ezra University, Los Angeles, Calif.;
- Francis University, Garden Grove, Calif.; and
- Sierra States University, Garden Grove and Los Angeles, Calif. (Note: "States" is correct, this is not a state university.)
All are small and fairly new. All accept foreign students. All, with the possible exception of the last one, appear to be at least nominal non-profits. All, with the possible exception of the first one, appear to be church-connected, largely evangelical. All of the presidents of the four entities have Asian names. All are in Los Angeles County, adjacent Orange County, or both.
The largest one barely had a gross income of $1 million a year, according to its most recent Form 990 filings with the IRS.
Before going further, it may be useful to make a quick summary of the regulation of such entities. There are three concepts: 1) state licensing; 2) DHS authorization for the admission of alien students; and 3) accreditation, which is routinely done by private entities that have been recognized by the U.S. Department of Education. The concepts are overlapping, and often lead to confusion.
One has to have a state license to operate and to accept foreign students. DHS does not demand accreditation, but to issue the I-20 (which leads to an F-visa) a school either has to have accreditation or to have its students accepted by three other DHS-recognized entities. The state regulators in California are in the Bureau for Private Postsecondary Education (BPPE), and it is part of the State Department of Consumer Affairs. BPPE does not require accreditation, as some states do, but many colleges seek it as a sort of merit badge. Accreditation entities need to be recognized by the U.S. Department of Education. There are specific accreditors, I suspect not too assertive ones, that deal with religious schools. Of all these players, DHS, through the Student and Exchange Visitor Program (SEVP, part of Immigration and Customs Enforcement (ICE)), is the least active.
Specifics of the KOJC Case
Any and all of these four entities has the formal credentials to do what has been charged in the KOJC case and which is described on pp. 31-32 of the criminal complaint in the U.S. District Court for the Central District Court of California (2:20-cr-00079-TJH).
In order to keep useful, fund-raising aliens in legal-migration status, KOJC arranged 82 phony marriages between citizens (presumably KOJC faithful) and the victimized fund-raisers. It also, and this is the area of interest, did the following (from p. 31 of the complaint):
f. In 2016, DUENAS [one of the conspirators] applied for a student visa on Victim H's behalf and enrolled her as a student at a university in California. Two years later, Victim H was enrolled at a different university in California. Victim H stated that classes were typically one day a week from 9:30 a.m. until 7:00 p.m., and that there were approximately 20 KOJC workers enrolled at the latter university. Victim H stated that she was forced to attend class, and the group was driven by another KOJC worker who was also a student. DUENAS was in charge of applying for the student visas of KOJC workers and enrolling them into universities.
The otherwise commendable complaint (for its thoroughness and clarity) notes on p. 32:
I understand that individuals who hold student visas and are currently in school (i.e., they have not graduated) are generally not allowed to work.
This is not correct, except for first-year foreign students seeking bachelor's degrees. Second-year undergrads and all graduate students are allowed to work from their first day on campus; this is one of the major attractions of graduate study at such places.
Apparently several universities were enlisted by KJOC in such activities; I cannot visualize how a university would not be aware of the motivation for these arrangements; these are small entities, and a block of 20 students attending only one day a week, and (presumably) having their tuition paid in a lump sum must have attracted some notice within the university.
My sense is that this would be an easy matter to investigate, and that such investigations might well lead to indictments of one or more individuals at each the four universities. The charge would be joining the conspiracy of KOJC to manipulate the immigration laws, or some such. I say this though I am not a lawyer. I also wanted to pass along the names of these institutions to state regulators and, if appropriate, to the accrediting agencies.
Specifics on the Four Colleges
CUBT. It reported $1,013,008 in program service income (i.e., tuition) in 2017, down about $100,000 from the prior year. It had no other income in 2017, but took a heavy loss of $272,526 by renting space it did not need. It would have been vulnerable to the KOJC proposal. It had no contributions in either 2017 or 2016. This is from the Form 990s on file.
Its president was, at that time, Wayne H. Huang. In its report to BPPE, it appears that its largest program was for MBA students, of which it had 95, all of which were "available for graduation", though only eight of them graduated. It claims no accreditation.
Ezra University. It reported $680,375 in tuition payments in 2017, up from $468,568 the prior year. It also had $146,000 in contributions in 2017 and $201,000 the prior year.
Its president was Hyoungnae Park. A person with this name, perhaps a different person, filed for bankruptcy in California in 2014. It claims to be a candidate for accreditation with the Association for Biblical Higher Education Commission on Accreditation.
Francis University. It reported $284,898 in tuition income in 2017 and $150,106 the prior year. It had contributions of $60,000 each year. There are numerous biblical citations on its website (as well as photos of a blonde young woman with perfect teeth.)
Its president on the Form 990s is Angela Han, and on its website it is Tiger Lee. Google searches for each of these people, accompanied by "Francis University" produced nothing.
It claims no accreditation. It is not a member of the Association of Franciscan Colleges and Universities. Most marginal colleges secure a listing in Wikipedia; neither Francis, nor Sierra States University has such a listing.
It is barely there, but at least it spells its own name consistently, and files Form 990s.
Sierra States University. Neither of the previous statements can be made about SSU. On its website it asks, in large letters: "Why Sierra State University?" The question, as phrased, would suggest that SSU is part of the prestigious California state system — it is not.
The lack of Form 990s may relate to its status as a for-profit institution, but there is no evidence one way or the other on this variable.
We will alert the two accrediting commissions and the California authorities of these finding.
Taking stock of the situation, one can see that the feeblest of tertiary institutions can swim through the DHS authorization process, despite wispy institutional profiles, despite, in one case, an institutional inability to spell its own name consistently.
It would be most helpful if the administration spoke sharply to the civil servants in SEVP, and told them to look at the dregs of higher education, and make it a tad harder for such feeble entities to cause the unbridled admission of such students, be they victims, as in this case, or simply those aliens taking advantage of the visa mills to get into this country without meeting any reasonable academic standards.
Why push controversial reforms — such as the new public charge requirements — and ignore the easy reforms, such as with the visa mills that we described at some length some years ago as the "Compromised Colleges"?