GN 00302.960 Use of Forms I-151 and I-551 as Proof of Age
Alien registration cards (Forms I-151 and I-551) do not necessarily reflect the same DB as that given to INS when the alien first entered the U.S. because the DB in INS' records may have been amended. INS makes such amendments without requiring much, if any supporting evidence.
No annotation is made on the subsequent I-151 or I-551 to show that the record was changed. This uncertainty about whether the DB was amended may or may not affect SSA's use of the card.
B. Use of forms as evidence of age
|The I-151 or I-551 was established before age 31||Use it as automatically convincing evidence of age as long as all of the other conditions in GN 00302.115 are met.|
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Any other situation exists
Follow the development guidelines provided elsewhere in this subchapter, and
Use judgment in determining whether it is necessary to ascertain the existence of an earlier INS record.
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C. INS assignment of January 1
INS arbitrarily assigns January 1 as the month and day of birth to a person who knows only his/her year of birth. In this situation, SSA's DB determination should disregard such a month/day indication.
SSA will use only the year of birth shown in INS records unless both of the following conditions are met:
January 1 is shown to be the refugee's month and day of birth on either the current SSA application or at least one other record, and
The claimant provides an explanation (which must be documented on an RC or signed statement) that shows he/she has some reasonable basis for using January 1 (i.e., a reason other than it is the date which INS assigned to him/her).
If only the year of birth is being established based on the INS record, use the instructions in GN 00302.480D. to establish the month and day.
D. Dates I-151 was revised
The I-151 has been revised periodically since being introduced in 1946, on the following dates:
1/77 (Form I-551)
E. Determining approximate recordation date of Form I-151—General
The I-151 does not show a recordation or issuance date. However, an approximate period of recordation can be deduced using:
Claimant's alleged date of entry into the U.S., and
Revision date of the I-151 presented, and
Date of the next revision.
Generally, INS continues to use the existing stocks of a previous version of the I-151 until it is exhausted before a new revision is used. You can assume that a given version was exhausted within 6 months of the date the next revision was issued.
The DB shown on the I-151 will be assumed to have been recorded
No earlier than the date of entry into the U.S.,
No later than the date 6 months after the date of the next revision of the I-151 (or I-551).
A RIB claimant presents an I-151 with the revision date of 7/1/46. She entered the U.S. on 9/10/47. Her alleged DB, 12/7/21, agrees with the DB on the I-151.
We assume that the I-151 was recorded between 9/10/47 and 7/14/49 (6 months after the next revision, 1/14/49).
NOTE: Provided the other requirements of GN 00302.115 are met, the SSA record plus the I-151 constitute first priority automatically convincing evidence since the entire possible recordation period was prior to the claimant's attainment of age 31. (If the WE had attained age 31 between 9/10 /47 and 7/14/49, the automatically convincing evidence guidelines could not be used unless INS is contacted for the actual recordation date, and that date was before the claimant became age 31).
H. More precision needed
If the probable recordation date deduced using the above rule is not precise enough for a particular situation, you may opt to contact INS to determine the actual recordation date of (and/or the DB shown on) the earliest INS record.