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Compiling Evidence in Advance

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I've been doing a lot of research on here to see what kind of paperwork will be needed for the ROC step of the immigration process and even though my husband's 2-year green card expires in November 2015 I know that it is never too early to start getting this stuff together. Based on the lists other people have posted of the materials that they send in with their I-751 form, I had some questions about establishing a legitimate marriage based on co-mingling of assets. My husband and I got married in June 2013 and I added him to my work health insurance in July as soon as he got his social security number, and we're filing our 2013 taxes this evening, but as of right now I think we're still lacking in some of the other major forms of proof. Help?

I have a pretty low-paying job and as yet my husband still hasn't been able to find a job so we have been living at my father's house since we got married, therefore we don't have a mortgage or renters' insurance or even a joint lease agreement because my father (thankfully) only accepts maybe $50 here or $100 there from us for rent/contribution to utilities and even that is pretty rare (the last time he asked for anything was before Thanksgiving). I guess a notarized letter from my dad saying that we live at his house and he only occasionally always accepts rent from us is enough? But then we never did any kind of receipt or anything whenever I gave him money so there's no concrete proof there. After we got married, I tried to add my husband to my checking and savings accounts but I was a member at a small, local bank (only exists in my state) and they said they would not add his name to my accounts until he got his green card -___-. He had been making internet transfers from his bank to my savings account so his name shows up on my statements a few times as making an electronic transfer into the account, but his name is not on the account itself as a co-owner. Would those statements with his name there as a transfer count as valid proof that we were at least trying to combine our finances? I finally learned from VJ that TD Bank would allow you to set up a joint bank account with only a social security number and a passport as form of ID so we did that, but if we got married in June we didn't have a joint bank account set up until September. After some begging I was able to get my former bank to write a letter on letterhead stating that we tried to set up a joint account with them but that they would not let us because my husband was not yet a permanent resident or citizen. Should I get that notarized or is it fine as is on letterhead and with a signature? My dad is also helping me put some of the household utility bills in our names but I was told by National Grid that they will not put two people's names together on the monthly bills, so the best they could do was put my name on the bill and then put my husband's name on the account as a contact. Considering it's a utility bill for gas/electricity is it really the case that they can't put two names on it? I found that odd, especially after seeing so many examples here of people saying they have utility bills in both names. Will a cable bill or a water bill suffice instead?

Another problem I have is that my job does not offer any form of retirement fund so I have no 401K or IRA account to which I can name my husband as a beneficiary, nor do we have any life insurance right now (our finances are stretched thin enough as it is with our health insurance taking a huge chunk out of my paycheck every 2 weeks, we can't really afford another payment for something else right now). I'm trying very hard to do these things one at a time because it's mind-numbingly stressful, and the next step after filing our taxes is for my husband to get his driver's permit. My final question is: if we've been married since June 2013, is it cause for concern that we're tackling these methods of proof one at a time and taking a while to do so rather than having them done within the first couple of months after we got married? I'm concerned about submitting the paperwork next year and then finding out that each month we get farther and farther from the month we got married will be another point against us. Sorry for the long message.

The Story So Far

K1 Visa Application/Approval

AOS Application Process

http://www.visajourney.com/timeline/profile.php?id=135643

ROC Petition Process

September 28, 2015..........................Mailed I-751 packet to VSC (regular mail from Providence, RI)

September 30, 2015..........................Packet received at VSC (signature confirmation)

October 5, 2015.................................VSC makes $590 ACH withdrawal from our bank account

October 6, 2015.................................NOA 1 Received in the mail (dated October 1, 2015)

October 15, 2015...............................Received Biometrics letter in the mail. Appointment set for 10/28/15.

October 28, 2015...............................Biometrics completed.

August 27, 2016................................Approval letter received in the maaaaaaaaaail! Letter is dated August 23, 2016. Now waiting for green card.

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Filed: Timeline

Based on my interactions with USCIS, I sense they will be understanding. If you live with family, you might bring mail addressed to both you and your husband as well as other family members at the same address, and perhaps the lease or deed in your father's name. USCIS will also understand if it takes a few months to get your finances co-mingled; what would be a red flag is if you did it all just prior to filing for ROC. Drivers licenses showing the same address will help. A slight caution, transfers from his account to an account in your name MIGHT be construed as him paying you for a sham marriage - I'm not saying these are a bad thing, just that I wouldn't emphasize them but rather just show that you opened joint bank accounts as soon as he got his green card.

I think you'll be fine.

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Based on my interactions with USCIS, I sense they will be understanding. If you live with family, you might bring mail addressed to both you and your husband as well as other family members at the same address, and perhaps the lease or deed in your father's name. USCIS will also understand if it takes a few months to get your finances co-mingled; what would be a red flag is if you did it all just prior to filing for ROC. Drivers licenses showing the same address will help. A slight caution, transfers from his account to an account in your name MIGHT be construed as him paying you for a sham marriage - I'm not saying these are a bad thing, just that I wouldn't emphasize them but rather just show that you opened joint bank accounts as soon as he got his green card.

I think you'll be fine.

Thank you so much for the reply. The more I read here the more I wonder if I was grossly underprepared for all of this. But rolling this all out gradually, doing one thing at a time, isn't necessarily something USCIS would have a problem with? My husband has a state ID right now because he's a bit nervous about learning how to drive, and it shows our address on it like my license does, but even then, the DMV in my state wouldn't let him even get an ID until he had his green card so it's only effective from January. I never thought of proof actually making USCIS think this was a sham marriage (lack of proof, maybe...)! Do you think that showing those couple of statements with his transfers but then also showing that we eventually set up a joint account and share the same address, share insurance, etc. might be enough to show that he wasn't paying me for a paper marriage or should I just leave those out completely and include the letter I got from my bank saying that it was against their policy to add his name to my account before his AOS so we just set one up as soon as we could?

If I could ask one more question, but have you ever heard of utility companies not adding two spouses' names on the same bill? Is that something I should talk to a manager over? Maybe that's just National Grid, but I keep seeing people say over and over that you should be adding each other's names to utility/house bills to show the same address and that you're paying bills together.

The Story So Far

K1 Visa Application/Approval

AOS Application Process

http://www.visajourney.com/timeline/profile.php?id=135643

ROC Petition Process

September 28, 2015..........................Mailed I-751 packet to VSC (regular mail from Providence, RI)

September 30, 2015..........................Packet received at VSC (signature confirmation)

October 5, 2015.................................VSC makes $590 ACH withdrawal from our bank account

October 6, 2015.................................NOA 1 Received in the mail (dated October 1, 2015)

October 15, 2015...............................Received Biometrics letter in the mail. Appointment set for 10/28/15.

October 28, 2015...............................Biometrics completed.

August 27, 2016................................Approval letter received in the maaaaaaaaaail! Letter is dated August 23, 2016. Now waiting for green card.

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