…equires a determination predicated on an opinion as to the likelihood of future events. [ 382 ] Accordingly, as set forth in proposed 8 CFR 212.21 , DHS proposes that an alien who is currently receiving public benefits is not necessarily inadmissible, because such current receipt…

…ion.” Response: DHS disagrees that it is at all problematic for DHS to consider events in the alien's past as part of a prospective inadmissibility determination. As explained in the NPRM, DHS's proposed totality of the circumstances standard involves the weighing of positive and…

…ion.” Response: DHS disagrees that it is at all problematic for DHS to consider events in the alien's past as part of a prospective inadmissibility determination. As explained in the NPRM, DHS's proposed totality of the circumstances standard involves the weighing of positive and…