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I would'nt have suffered a 485 denial had there been no LC Substitution. I know my company revoked I140 after I used AC21 to use the LC for someone else. (Ofcourse I paid every dime for that whole process)
Here are my comments I sent o DOL on the proposed LC Substitution elimnation rule. You can email at 'fraud.comments@dol.gov' with RIN 1205-AB42 in the subject line.
I did not have time to write a much polished letter. Anyways this is what I came up with.
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Sub: Substitution Elimination Proposed Rule
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.
1. Employers routinely layoff those employees for whom Labor has been approved and later use those labors for someone else in a future date.
2. Buying and Selling of labor certifications is quite prevalent.
3. Lawyers are often party to exploiting employers. So it is not surprising that lot of them are opposing these proposed rules.
4. 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
5. 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,
Here are my comments I sent o DOL on the proposed LC Substitution elimnation rule. You can email at 'fraud.comments@dol.gov' with RIN 1205-AB42 in the subject line.
I did not have time to write a much polished letter. Anyways this is what I came up with.
----------------------
Sub: Substitution Elimination Proposed Rule
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.
1. Employers routinely layoff those employees for whom Labor has been approved and later use those labors for someone else in a future date.
2. Buying and Selling of labor certifications is quite prevalent.
3. Lawyers are often party to exploiting employers. So it is not surprising that lot of them are opposing these proposed rules.
4. 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
5. 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,