Representation as Reputable Individual: possibility or merely lip service?

Under 8 CFR § 292.1 - Representation of others, item (a)(3), I should be allowed to appear before an immigration officer to represent an individual at the request thereof, provided I am of good moral character, not remunerated for my appearance, and my "appearance is permitted by the DHS official". I'm not a lawyer/attorney/law student, but neither does 292.1(a)(3) require one to be. Has anybody tried this in practice?

A dear friend of mine, who is old and has limited spoken English proficiency, is about to have his naturalization interview. He's going on general terms (no disability, not eligible to take the exam in his native language). He's extremely sharp and his written English is superb; he knows the questions like the back of his hand, but what's impaired is listening comprehension. He is extremely worried about the technical communication overhead (getting through security, navigating the building to the point of getting to the actual interview location, getting post-interview instructions) as well as the "small talk" part of the interview (where questions can be unpredictable - the weather? how his day has been? something else?) He's afraid that he won't catch those questions, won't be able to answer them and will fail the test as a result.

Now back to 8 CFR § 292.1. I had an idea: I exercise my right to represent him under this paragraph; go in with him and guide him through all the hurdles, then step aside for the actual exam. But how to accomplish this in practice? I thought I could use form G-28 for that, but it specifically says that it's not for the "reputable individual" route. The instructions say: _"Individuals seeking to appear as reputable individuals may not use Form G-28. They must obtain permission from DHS to appear on behalf of an applicant, petitioner, requestor, beneficiary or derivative, or respondent. DHS will require the individual establishes he or she meets the definition of a reputable individual at 8 CFR 292.1(a)(3)"_ and do not elaborate on HOW this permission from DHS can be obtained. I tried to call USCIS about that, but their new system is not conducive to meaningful conversation (I made a separate post about that called "USCIS Phone System).

What would it take for me to get cleared to represent my friend at his naturalization appointment just to help him overcome those routine language challenges? Or perhaps the provision of § 292.1(a)(3) exists only on paper, with no mechanism to implement it?

submitted by /u/tsaudreau
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