Yesterday, the DOL issued a new memo explaining that it will start requiring all secondary employers to file LCA’s for contractors placed at their location. The DOL cites to a new USCIS regulation which is expected to be issued on Tues the 19th which changes the definition of an employer. The DOL specifically states that this memo “better comports with the goals of the Executive Branch policy” The new memo will take effect on July 14, 2021. The Wage and Hour Office also issued a Field Assistance Bulletin implementing the above memo. It is expected that the new Biden Administration will examine this new policy.