Neufeld Memo - "If an application or petition lacks the required initial evidence, USCIS may deny the incomplete application or petition, though adjudicators are urged to exercise this option judiciously, or issue a request for evidence (RFE)" (Available on internet at uscis.gov)
Yates Memo - "A denial without RFE or NOID should only occur when there is clear evidence of ineligibility." (available on internet at uscis.gov)
That means only in a gross mistaken cases only they can deny it directly.
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