March 31, 2011
New Arranged Emploment Opinion (AEO) Forms Raises Some Concerns
Section 55 on the new AEO forms released this Monday reads:
“Please list any type of payment the employer, its representative(s), or any other third party received in connection with the job offer or for obtaining a positive arranged employment opinion”
Does this mean representatives must now disclose retainer arrangements for legal services performed in preparing an AEO? Also, there is also discussion of Substantially the Same (STS) guidelines in the new forms suggesting the scope of the STS regime will include AEOs.