Thanks for your question.
Assuming you otherwise meet the eligibility criteria and the end of your 5 year period is 19/11/2011 the earliest date you could apply for ILR would be 22nd November 2011, which is obviously 28 days before 19/11/2011. I always advise my clients to date/send their application on the first day they are eligible to apply by registered post.
Date your application and covering letter 19/11/2011 and send it on that day and you will be fine.
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did you mean 22 october in your answer as you said this in your answer "the earliest date you could apply for ILR would be 22nd November 2011, which is obviously 28 days before 19/11/2011"
Yes, that's correct.
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