the 2016 Republican National Convention. In early polls on the 2017 gubernatorial race, Cuccinelli was a frontrunner for the Republican nomination. However, in April 2016, Cuccinelli announced that he would not run for governor in 2017. In May 2016, Cuccinelli was named general counsel of the FreedomWorks Foundation, where he helps state attorneys general who want to oppose a federal regulation. In January 2017, Cuccinelli filed a legal brief on behalf of the Virginia Poverty Law Center, challenging a 2015 law which freezes base electricity rates charged by Dominion Power, one of the state's most powerful corporations, and Appalachian Power Company. The basis of the brief is that the law allows these semi-public electric utility companies to charge excess rates. Cuccinelli said "This is a legalized transfer [of money] from poorer Virginians to two utility companies. It is unfair and unjust and unconstitutional, and it's bad policy." De facto Acting USCIS Director (2019–2021) Cuccinelli was appointed to serve as the Principal Deputy Director of the United States Citizenship and Immigration Services (USCIS) in June 2019, allowing him to become the Acting Director. As the administrator of USCIS, Cuccinelli was in charge of the systems for legal immigration and naturalization. He said that he regarded access to immigration as a privilege, not a right, and that "We are not a benefit agency, we are a vetting agency." Appointment controversy Cuccinelli was appointed Acting Director when leading Senators indicated he had little chance of Senate confirmation as permanent director. He was first appointed to a newly created position of "Principal Deputy Director", which according to Department of Homeland Security officials allowed him to then be appointed as Acting Director under the Federal Vacancies Reform Act (FVRA). The appointment as Acting Director of USCIS may have circumvented the Federal Vacancies Reform Act, according to the Chairs of the House committees on Judiciary, Homeland Security, and Government Oversight. FVRA stipulates eligibility criteria for temporarily filling positions that require Senate confirmation. Before being considered for the position, Cuccinelli had met none of the eligibility criteria. In a letter to the Acting Secretary of Homeland Security, the House committee chairs allege that the brief appointment to "Principal Deputy Director" had been retroactively applied, possibly in violation of the law. The USCIS employees union also challenged the legality of Cuccinelli's appointment. In September 2019, a lawsuit was filed challenging his asylum directives, partially on the basis that