u/Jumpy_Cheetah_8699

Got an EB-2 NIW RFE under Matter of Dhanasar for a software engineering / financial infrastructure petition and would appreciate advice from anyone who has successfully responded to similar RFEs, especially in technical fields.

Background:

• STEM Master’s degree
• Work focuses on low-latency market data infrastructure, real-time risk aggregation, and reliability of financial systems
• Petition framed around strengthening the resilience and integrity of U.S. financial market infrastructure

TL;DR of original petition strategy:

The petition framed my work as infrastructure engineering for modern automated U.S. financial markets, specifically:

• low-latency market data systems,
• real-time risk aggregation,
• and operational resilience during volatile market conditions.

Core theory:
When market data or risk systems fail under stress, problems can propagate across firms simultaneously, causing stale data, incorrect positioning, liquidity disruptions, amplified volatility, and broader market instability.

The petition argued this is not just internal employer tooling, but foundational infrastructure tied to:

• market integrity,
• financial stability,
• and U.S. economic competitiveness.

The proposed endeavor was framed as:

>“strengthening the technological resilience and integrity of U.S. financial market infrastructure by ensuring prompt, accurate, and reliable processing of market data and timely monitoring and aggregation of risk.”

For national importance, the petition relied heavily on:

• SEC statements about latency-sensitive market infrastructure,
• Federal Reserve materials describing financial market infrastructure as systemically important,
• and White House / National Security Strategy language about U.S. financial markets being critical to national power and economic leadership.

For “well positioned,” the petition emphasized:

• strong technical background,
• distributed systems experience at a major tech company,
• current ownership of production trading infrastructure,
• low-level C++ systems engineering,
• and hands-on responsibility for real-time market/risk systems operating under live conditions.

Recommendation letters came from:

• a trader at a major quant trading firm,
• an algorithm engineer at another major quant firm,
• my direct manager,
• and an economist / former central bank researcher.

The letters mainly argued that:

• failures in market data/risk infrastructure can create cascading market disruptions,
• resilient infrastructure benefits the broader financial system beyond one employer,
• and my work contributes to reliability/stability in automated financial markets.

The officer explicitly acknowledged:

• EB-2 qualification is met
• The endeavor has substantial merit

But issued an RFE on all 3 prongs.

Main themes of the RFE:

• USCIS says I focused too much on the importance of the financial infrastructure / fintech industry generally instead of demonstrating broader implications of my own specific endeavor
• They repeatedly say the petition did not sufficiently show impact beyond a single employer
• They argue the recommendation letters were too broad/conclusory and lacked concrete evidence of field-wide impact or unusual influence
• They say the record doesn’t establish that my methodologies/work are sufficiently innovative or distinct from standard industry work
• For “well positioned,” they say the evidence shows competence but not a strong enough record of success, recognition, influence on the field, or proof that the work has been adopted/used more broadly

The overall message of the RFE seems to be:

>“You established that the field is important, but not that your own specific endeavor/work has broader national implications beyond benefiting your employer.”

Questions:

1. Has anyone successfully overcome this kind of “you only benefit your employer” RFE?
2. Any tips?

I can share full redacted version of the RFE.

Preface by saying, I have already been in the industry for about 3 years as dev so hopefully this isn't a banned question. Lately I but have developed strong interests in microstructure and actual trading strategies and wondering how common and realistic it is to make the transition towards say being a trader (I use this loosely to mean anyone involved with figuring out or executing strategies from not a purely dev pov) for a desk? Is that an unrealistic thing to attempt?

My instinct is it should be possible if I say start as a dev for a specific desk and slowly while interacting with the PM and traders, learn the ropes and slowly take on more trader/quant like responsibilities. But figured I would ask if that makes any sense or if I am being delusional or if there is a better way to go about this.