persons are more likely to experience compared to other foreign nationals. 536 The “establishment” factors include: • The length of time the applicant has been in Canada • Were the circumstances that led the applicant to remain in Canada beyond their control? • Is, or was, the applicant the subject of a temporary suspension of removal? • To what degree has the applicant co-operated with the Government of Canada, particularly with regard to travel documents? Did the applicant wilfully lose or destroy travel documents? • Does the applicant have a history of stable employment? • Is there a pattern of sound financial management? • Has the applicant remained in one community or moved around? • Has the applicant integrated into the community through involvement in community organizations, voluntary services or other activities? • Has the applicant undertaken any professional, linguistic or other studies that show integration into Canadian society? • Do the applicant and their family members have a good civil record in Canada? (e.g. no criminal charges or interventions by law enforcement officers or other authorities for domestic violence or child abuse).537 In the “establishment” factors, it is noteworthy that statelessness is not a consideration for “circumstances that lead them to remain in Canada beyond their control.” Furthermore, whether the individual went “underground” and remains in Canada illegally is not considered beyond the person’s control. This is the case even if a stateless person goes underground to avoid potential indefinite detention or forced removal to a country where they have no status and would not have been received, or would not be provided with travel documents.538 Finally, another obstacle to applying for an H&C is that stateless persons may be so economically marginalized that they are unable to afford the necessary $550 fee to submit an H&C grounds application.539 III. Assessment Aside from the grant of citizenship in circumstances of stateless children born abroad to Canadian parents born abroad, there are no naturalization options specifically targeting the precarious circumstances of stateless persons in Canada. While a stateless person could potentially have some of the litany of factors used to consider an H&C application, the fact that they often live a marginal socio-economic existence means that the above permanent resident programs do not provide an effective remedy. Simply being stateless has not been enough on its own to receive a positive H&C decision. Statelessness in the Canadian Context, supra note 4 at 48. Citizenship and Immigration Canada, “The humanitarian and compassionate assessment Establishment in Canada” (24 July 2014), available at: http://tinyurl.com/p67tro8. 538 Ibid. 539 Statelessness in the Canadian Context, supra note 4 at 47; and Citizenship and Immigration Canada, “Guide 5291 - Humanitarian and Compassionate Considerations” (21 November 2014), available at: http://tinyurl.com/oohyeb3. 536 537 111 111