Recently in a meeting with the USCIS Field Operations Directorate, USCIS clarified when naturalization applicants with pending N-400s are required to file a Form I-90 to renew an expiring permanent resident card (I-551), and explained when USCIS can issue an Alien Documentary Identification and Telecommunication (ADIT) stamp as temporary proof of permanent residence without proof of a pending I-90:
1. If your green card will expire within six months of filing for naturalization you must also file Form I-90 with the filing fee to renew your green card.
• In order to obtain an ADIT stamp, these individuals must provide the USCIS Field Office with a Form I-90 receipt notice.
2. If your green card has at least 6 months of validity remaining, you are not required to renew your green card by filing Form I-90.
• You may receive an ADIT stamp without presenting a Form I-90 receipt notice.
• If you wish to apply for naturalization and without incurring the added expense of renewing your green card, you should file for naturalization while your green card is still valid for at least 6 months. This will save your $540.
USCIS’s guidance appears to originate from 8 CFR §264.5(b)(2) which provides, “A permanent resident shall apply for a replacement Permanent Resident Card … when the existing card will be expiring within six months….” Moreover, both the September 29, 1999 INS memorandum, Form I-551 Renewal Policy and Procedure-Interim Process and the subsequent February 1, 2002 memorandum, Form I-551, Permanent Resident Card, Renewal Policy and Procedure-Final Phase; Process for I-90s, note that INA §264(e) makes it a misdemeanor offense subject to a fine of $100 and/or imprisonment for not more than thirty days for failing to carry a certificate of alien registration or alien registration receipt card at all times.
The 2002 memo further notes, in reliance on 8 CFR §245.5(b)(2), that “a Form I-90 renewal application may be filed up to six months prior to the expiration of the card, or on or after the expiration date.” Thus, an LPR who files an N-400 when the I-551 is still valid for 6 months or more, and who wishes to extend their I-551 in lieu of obtaining an ADIT stamp, should refrain from filing Form I-90 until the I-551 will expire in less than 6 months.
The take away from this is to file your naturalization application more than six months before your green card expires and to carry your green card.
(This page was updated to show the new filing fees)
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USCIS announced today that, in conjunction with the Department of State (DOS), it is revising the procedures for determining when an application for adjustment of status may be filed, thus implementing part of President Obama’s November 2014 executive actions on immigration. Starting with the Visa Bulletin for October 2015, there are two important dates listed on the monthly Visa Bulletin: the “filing date,” which determines when individuals can submit their permanent residence applications, and the “final action” date, which indicates when DOS or USCIS can make a decision on the applications.