Quick update on this in case a similar situation comes up again: DSO wanted to learn if I will get paid. After I told them I won't be getting paid, they said they are fine with me officiating the wedding. However, when I mentioned I was planning to file I-485, they were hesitant to advise me on it and told me to contact a lawyer. I then posted the question on a website where immigration lawyers answer questions. I received 4 replies: 2 lawyers said it wouldn't be an issue, 1 lawyer said I should be careful and make sure the CO understands that a payment, tip, or even buying a beer wouldn't be involved, 1 lawyer outright said "it could be interpreted as work and a violation of F-1 status".
This entire experience has lead me to conclude that it's really up to the CO's interpretation. Given:
- My case number is high and a delay in the adjudication due to an RFE could be detrimental,
- We are at a time of increased scrutiny and vetting,
- Frontloading the application with information about not getting paid for officiating could backfire if it prompts the CO to start asking questions,
- Proving something did not happen (payment) is extremely difficult,
I've made the choice not to officiate the wedding or get ordained.