After sixteen years, the U.S. Department of Labor (DOL) proposed
a new PERM Form in the Federal Register. Employers,
foreign workers, attorneys, agents, and preparers may be parties to
a PERM application and are required to sign the form. Regrettably,
both the old and new forms fail to distinguish between the roles
played by agents and attorneys.
One peculiarity of the PERM Rule is that attorneys and agents
are treated equally. Both can represent clients before the agency,
because DOL does not limit representation to licensed attorneys.
DOL does not have a specific type of notice for attorneys at law to
declare their representation of a client.
DOL permits any person - physical or corporate, domestic, or
foreign - to represent employers throughout the PERM process and to
collect fees for their assistance. DOL does not question the
qualifications of non-attorneys who may engage in the unlawful
practice of law. If a person identified as an attorney is
guilty of
