Hello experts,
I am eligible to apply for Canadian citizenship and have added two months of buffer time for the number of days.
I am waiting for FBI police clearance certificate to arrive before I can send my application. It seems FBI has put a hold of issuing these due to the coronavirus crisis. I am not sure when they will resume the processing. I am wondering if I can send my citizenship application without the FBI police certificate. Can I update my file later once I receive the clearance certificate? If possible, I don't want to delay the citizenship application process.
What are your thoughts? Shall I send the citizenship application or wait for FBI police clearance certificate to arrive? Has anyone experienced similar issues in the past where you sent your application without Police clearance from a foreign country? Did they reject your application or requested additional information? Did this further delay your citizenship application process?
Thanks in advance for sharing your insights.
For purposes of making a "complete" application, an applicant can enter an explanation for why a police certificate is not included even if the applicant checked [yes] in response to item 10.b) The applicant who checks [yes] then lists the respective country in the chart provided. Then, instead of including a certificate, the applicant can provide an "explanation" in the chart. That should pass the completeness screening.
Basically the completeness screening checks to see if item 10.b) is checked [yes] and if so, checks to be sure EITHER a certificate is submitted OR an explanation provided.
If you have a definitive source ("
it seems . . . " not being anywhere near enough to base a decision on) that the FBI has put a hold on issuing clearances, you can list the U.S. in the chart and explain that a certificate has not been provided because the U.S. has a hold on issuing certificates. This should pass the completeness screening, avoiding the return of the application for not being complete.
But of course the completeness screening only determines whether the application is accepted for processing. So getting past the completeness screening does not necessarily mean all is well and will for sure be OK.
Thus, WHETHER or NOT to do this is a separate question. There are weighty reasons for WAITING until you obtain and can submit the clearance with the application.
So, in terms of the result albeit not necessarily the reasoning, I concur with what others are suggesting if not overtly stating:
probably best to wait to get the clearance and submit it with the application.
LONGER, MORE IN-DEPTH OBSERVATIONS:
It is not likely the validity of the "explanation" or reason for not including the certificate is evaluated, at least not closely evaluated, during the completeness screening. As already noted, basically the completeness screening checks to see if item 10.b) is checked [yes] and if so, checks to be sure EITHER a certificate is submitted OR an explanation provided.
That said, if the applicant's reason is, say, "
my cat told me not to submit a certificate," maybe that would not pass the completeness check. Or, say, "
I have not requested a clearance." I don't know to what extent the agent screening for completeness might substantively evaluate the content of the "explanation" for acceptability, rather than merely checking off that there is either a certificate or an explanation given. We do know their function is largely robotic, more akin to checking items on a checklist rather than making judgment calls. But during the completeness screening they do check what the applicant reports about status against the client's GCMS records, and have returned applications even though the presence calculation, as submitted, showed the presence requirement was met if that depended on having status for a period of time which GCMS does not confirm. This requires some degree of evaluation more substantive than merely checking items off a checklist.
Even if a not actually valid "explanation" gets a pass in the completeness screening, obviously an applicant should take extra pains to be certain that his or explanation is in fact true and valid. The threshold here is not what would constitute an overt misrepresentation. Other than in the more blatant cases, IRCC often does not take action against a lot of what they otherwise perceive to be misleading or even false, but any such perception can and will hurt the applicant's credibility. And second only to meeting the requirements themselves, the applicant's credibility is probably the next most important factor in how things go.
Thus, as already stated, WHETHER or NOT to do this, to apply sooner and give an explanation for why no clearance is included, is a separate question. Among considerations in making this decision, being CERTAIN the explanation is valid looms very large.
Be aware that of course IRCC will readily know what the actual U.S. policy and practices are. So you want to be certain of your facts before you make a representation to IRCC. Even though the application should get past the completeness screening, and even if you obtain and timely submit the clearance in a supplemental submission, eventually a processing agent or the citizenship officer will review the entirety of the application and if you make a misleading assertion as a reason for not including a certificate with the application, that could hurt your credibility . . . with NO mention of it, no direct question or challenge. Just something that elevates the level of scrutiny and perhaps invites skepticism.
Then there is the matter of what is to be gained or lost, the usual risk-analysis. With rare exceptions, waiting longer to apply is not likely to delay taking the oath by much and in many circumstances can facilitate actually getting to the ceremony and getting a certificate of citizenship sooner. (Big exception was in the spring of 2015, when waiting past June 10th could have rendered an otherwise qualified applicant ineligible for as much as another year or even two.) Given the current crisis and its impact on virtually every aspect of government functions, there will almost certainly be a significantly longer timeline for citizenship application processing, for all applicants, in which a couple or three months difference in when the application was made is not likely to be of much import.
And the latter may especially warrant consideration in the context here. During periods of time when citizenship application processing involved big backlogs, there was often a profound disparity in impact on applications involving non-routine processing. This seems like a period of time in which the prudent applicant will want to make an extra-special effort to avoid creating non-routine processing triggers. Bottom-line here is that when citizenship application processing slows, it tends to be a lot, lot slower for those tangled in any non-routine processing. (While my own experience was many years ago, when I applied the difference between smooth-sailing routinely processed applications and non-routine applications, could be two to three years, or even more -- when I applied, my application took barely eight months from date of application to date of the oath, with some of those taking the oath with me having applied barely six months earlier, while many other applicants endured two-to-four years of processing.)
Thus, for example, providing an explanation rather than the certificate may suffice to get past the completeness check, but perhaps it will trigger some non-routine processing, ranging from a fingerprint request that might not otherwise have happened, to other non-routine procedures, such as requests for U.S. entry records (some applicants with extensive stays or contacts in the U.S. appear to be prone for RQ-related non-routine requests; whether the risk of this might be affected by providing an explanation rather than the certificate, I do not know, but is easy to apprehend it might).
Yeah, the long, long way round to saying what others suggested far more succinctly: best to wait, to submit the clearance with the application.
