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Half Of PERM Is Already Here

The PERM proposed rule has two distinct components - (1) The substantive and (2) The structural. The substantive part of the rule includes the well-known provisions concerning attestations, audits, business necessity, etc. - this part has gotten the most press until recently. However, it is the structural part of the PERM concept which is perhaps where the impact on labor cert processing is much greater - the structural part consists of the elimination of the SWAs from the process, and centralizing/federalizing the labor cert program. Through the backlog reduction rule promulgated in August, and through the recent Transitional Guidance Memo (the TG) issued by the DOL, the structural changes contemplated in PERM have been almost completely implemented. Attorneys should realize that the TG portends greater practical change in the LC program than even GAL 1-97 did many years ago. And this change is not theoretical, it is already here - for example, the California Regional Office of the DOL has been more or less eliminated at this point (save for a very small number of active cases). We believe that the impact of the TG should not be underestimated. The TG will be among labor cert issues discussed at the final session of "Preparing For PERM With Joel Stewart" The deadline to register is Wednesday, November 3rd. For more info, detailed curriculum, speaker bios, and registration information, see: (Fax version: