Recent CFGI Comments and New Comment Opportunity


​CFGI and its affiliate, SHRM, recently submitted comments on the following:

Unfair Immigration-Related Employment Practices

In comments to the Department of Justice Civil Rights Division, CFGI and SHRM joined with other stakeholders to raise several concerns regarding the breadth and process changes proposed.  Specifically, the comments express concern about:

  •  The Office of Special Counsel's investigative powers exceeding statutory authority;
  • The proposal to make "disparate treatment" without any discriminatory purpose or intent an actionable ground of discrimination;
  • Expansion of time limits within which cases may be brought.

CFGI and SHRM also submitted separate comments noting that the burden estimate in the rule was very low and that the rule is likely a "significant rule" requiring further analysis pursuant to the Administrative Procedure Act.

International Entrepreneurs

While CFGI and SHRM support United States Citizenship and Immigration Services' efforts in ease the immigration process for entrepreneurs, our comment makes several recommendations for improvement including:

  • Allowing for an initial one year parole period for entrepreneurs to seek investments;
  • Adjusting investment thresholds to ensure entrepreneurs have a reasonable avenue for parole; and
  • Adjusting income level required for an individual to maintain parole  

DHS Regulatory Review

The Department of Homeland Security seeks comments from the public on specific existing significant DHS regulations that the Department should consider as candidates for streamlining or repeal. Comment are due November 10, 2016.

To see the latest on all of the regulations and rules important to employers of highly-skilled foreign nationals, visit our regulatory tracker.