August 15th, 2007 — Following up on our earlier announcement, the ICE Final Rule on safe-harbor procedures for employers who receive "no-match" or similar letters from SSA or DHS was published in the Federal Register today. Unless subsequently modified or withdrawn, this Final Rule takes effect for employers on September 14th, 2007. How the rule will apply to "no-match" or similar letters from SSA or DHS received before that date is unclear, but employers would be wise to assume that ICE will consider such prior letters as "constructive notice."

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