What if my client has failed to re-register for more than one re-registration period for his or her country?

Typically, the longer the delay in applying to re-register, the more compelling the applicant’s “good cause” reason(s) may need to be. However, late re-registration has been granted to TPS beneficiaries who failed to register during more than one re-registration period.  In such cases, consider including evidence of the good cause for late filing in addition to evidence that the applicant continues to meet the requisite continuous residence and other eligibility requirements for TPS.

Good causes might include unemployment, family emergency, language barriers. So write down a letter explain one of the "good cause' reasons clearly, and explain that the reason for filing late. 

If a re-registration application is denied, will USCIS issue a Notice to Appear?

Good luck!!!