Cancellation of removal for LPRs is available to noncitizens who obtained their LPR status by fraud as long as the fraud is waived (for example under INA 237(a)(1)(H), 8 USC 1227(a)(1)(H)), before the application for cancellation of removal is made (though both may occur in a single removal proceeding). Matter of Sosa-Hernandez, 20 I. N. Dec. 758 (1993) (where immigration judge grants the permanent resident fraud waiver, permanent residency becomes valid as of the day that it was originally granted); Matter of Kolomatangi, 23 I&N 548 (BIA 2003). But see Matter of Ayala, 22 I&N 398 (BIA 1998) (permanent resident who asserted he obtained that status by fraud because of undisclosed criminal activity was held permanent resident for purposes of the bars to 212(h) relief).