.New DOL regulations affecting the PERM labor certification application process go into effect on July 16, 2007. Please note that after that date, employers will no longer be able to substitute foreign national beneficiaries on approved labor certification applications. Additionally, there will be a limited period of time for Form I-140 Immigrant Petition filings upon labor certification application approval (i.e., 180 calendar days), and a requirement that employers pay the costs of preparing, filing, and obtaining the labor certification. If you are currently holding onto any approved labor certification applications either with hopes for substitution of beneficiaries or as a “safety blanket” for a foreign national pursuing permanent immigration via family or other sponsorship, discuss your further strategies with immigration counsel as soon as possible