A blue-ribbon team of American Immigration Lawyers Association (AILA) members has been assembled to prepare AILA's comment on the regulation proposed by Dept. of Labor on February 13, 2006. Among the issues in the regulation that the team plans to address:

• the proposed absolute prohibition against substituting aliens on labor certifications;
• the proposed limitation on validity period of the labor certification to only 45-days;
• the proposed interference with the attorney/client relationship in prohibiting the alien from paying attorneys fees and other expenses for the labor certification application;
• the proposed imposition of new penalties and standards for penalizing suspected fraud; the proposed prohibition against amending PERM applications.

In addition to the AILA comment, model comments will be prepared for use by individual AILA members and their corporate clients.