GreenCardVirus
Registered Users (C)
Sub: Substitution Elimination Proposed Rule RIN 1205-AB42
Dear Sir and Madam:
I sincerely appreciate DOL for proposing these new rules. As a beneficiary of 3 separate Labor Certifications from 3 different companies over a period 8 years, I can only say that the provision for Labor Substitution has been very widely abused in the Green Card Process.
Apart from the 45 day LC validity rule, DOL got it right on every other rule. 45 days might be too less for someone to get I-140 filed with USCIS.
Employers routinely layoff those employees for whom Labor has been approved and later use those labors for someone else in a future date.
Buying and Selling of labor certifications is quite prevalent.
Lawyers are often party to exploiting employers. So it is not surprising that lot of them are opposing these proposed rules.
Employers often make employees to pay for Green Card expenses. It is only logical that Employers pay for the process if their business is so dependent on Foreign Labor
Lot of companies who file multitude of Labor Certifications exclusively hire foreign employees only. Saying that not one US citizen is available is factitious at best.
DOL’s proposed rules for Elimination of Labor Substitution is a policy in the right direction that protects righteous well meaning employers as well as unsuspecting workers.
Thanks,
Dear Sir and Madam:
I sincerely appreciate DOL for proposing these new rules. As a beneficiary of 3 separate Labor Certifications from 3 different companies over a period 8 years, I can only say that the provision for Labor Substitution has been very widely abused in the Green Card Process.
Apart from the 45 day LC validity rule, DOL got it right on every other rule. 45 days might be too less for someone to get I-140 filed with USCIS.
Employers routinely layoff those employees for whom Labor has been approved and later use those labors for someone else in a future date.
Buying and Selling of labor certifications is quite prevalent.
Lawyers are often party to exploiting employers. So it is not surprising that lot of them are opposing these proposed rules.
Employers often make employees to pay for Green Card expenses. It is only logical that Employers pay for the process if their business is so dependent on Foreign Labor
Lot of companies who file multitude of Labor Certifications exclusively hire foreign employees only. Saying that not one US citizen is available is factitious at best.
DOL’s proposed rules for Elimination of Labor Substitution is a policy in the right direction that protects righteous well meaning employers as well as unsuspecting workers.
Thanks,