Sponsoring a PERM Labor Certification and Employment-Based Green Card

The process has three sequential government filings and takes anywhere from eighteen months to a decade, most of which is waiting.

1. PERM labor certification with the Department of Labor — a test of the U.S. labor market.
2. Form I-140 immigrant petition with U.S. Citizenship and Immigration Services — establishing the employer's ability to pay and the worker's qualifications.
3. Adjustment of status or consular processing — the actual grant of permanent residence, available only when a visa number is available.

The first step is not required for every category, and the most consequential planning decision an employer makes is whether it can avoid it. The second step establishes a priority date that determines when the third becomes available. And for nationals of a few heavily oversubscribed countries, the wait between the second and third steps can exceed a decade — a fact that should shape the plan from the beginning.

Choosing a category

EB-1A — Extraordinary Ability. Self-petitioning; no employer and no PERM required. Requires sustained national or international acclaim, evidenced by a major internationally recognized award or at least three of ten regulatory criteria, plus a showing that the beneficiary is among the small percentage at the very top of the field. High standard, and current or near-current for most countries.

EB-1B — Outstanding Researcher or Professor. Employer-sponsored, no PERM. Requires international recognition as outstanding in a specific academic area, at least three years of experience, and a permanent research position or tenure-track offer.

EB-1C — Multinational Manager or Executive. Employer-sponsored, no PERM. Requires one year of employment abroad in the preceding three years with a qualifying related entity in a managerial or executive capacity, and a U.S. offer in the same capacity. The natural progression from an L-1A.

EB-2 — Advanced Degree or Exceptional Ability. Requires a U.S. master's or higher, or a bachelor's plus five years of progressive experience, or exceptional ability. PERM required unless the beneficiary qualifies for a national interest waiver.

EB-2 National Interest Waiver. Self-petitioning and no PERM. Under the Matter of Dhanasar framework, requires that the proposed endeavor have substantial merit and national importance, that the beneficiary be well positioned to advance it, and that on balance it would be beneficial to the United States to waive the job offer and labor certification requirements. Increasingly used and increasingly scrutinized.

EB-3 — Skilled Workers, Professionals, and Other Workers. Bachelor's degree, or two years of training or experience, or (for "other workers") less than two years. PERM required. Lower standard than EB-2, sometimes with a better priority date depending on the country and the moment.

EB-4 — special immigrants, including religious workers. EB-5 — investors, covered separately.

Planning implications:

• Always evaluate whether a no-PERM category applies. It saves twelve to eighteen months and a great deal of expense and risk.
• EB-2 versus EB-3 is a strategic choice, not merely a classification. Priority dates for the two categories move independently and sometimes invert, and a beneficiary may hold approved petitions in both.
• File early. The priority date is established by the PERM filing (or the I-140 filing where no PERM is required), and it is the beneficiary's place in line. For a national of an oversubscribed country, a year of delay in starting can be several years of delay in finishing.

Before recruitment: the prevailing wage determination

The employer must offer at least the prevailing wage for the occupation in the area of intended employment, and must obtain a determination from the Department of Labor's National Prevailing Wage Center by filing Form ETA-9141.

What the request specifies:

• The job title and duties, in enough detail to permit occupational classification.
• The minimum requirements — education, experience, training, special skills, and any supervisory duties.
• The worksite location or locations.
• Whether travel is required and where.

How the determination is made. The Center assigns an O*NET occupational code, evaluates the requirements against the occupation's normal requirements to assign a wage level from I (entry) through IV (fully competent), and issues a wage from the Occupational Employment and Wage Statistics survey — or from an employer-provided alternative survey meeting regulatory criteria.

The wage level is driven by the requirements the employer states. Requiring a master's degree, five years of experience, supervisory duties, or unusual skills pushes the level up and the wage with it. This is the first place where the requirements analysis has consequences.

Timing. Processing times have varied widely and have run several months. Build it into the plan, and note that the determination has a validity period within which the recruitment must begin or the application must be filed.

If the wage is too high, options are to request a redetermination, to submit an acceptable alternative wage survey, to reconsider the stated requirements if they exceed what the job actually needs, or to pay it. Do not lower the requirements below what the job genuinely requires to reduce the wage — the requirements must be the employer's actual minimum requirements, and a mismatch creates a different problem.

The requirements analysis

This is where PERM applications are won and lost, and it deserves more attention than the recruitment mechanics.

The governing principle, from 20 C.F.R. § 656.17(h): the job opportunity's requirements must be the employer's actual minimum requirements for the position, the employer must not have hired workers with less training or experience for substantially comparable jobs, and the requirements must be normal to the occupation — or, if not, justified by business necessity.

Business necessity requires showing that the requirement bears a reasonable relationship to the occupation in the context of the employer's business and is essential to perform the job in a reasonable manner. It is a real burden and it is examined in audits.

The experience-with-this-employer problem. § 656.17(i) generally prohibits requiring experience the beneficiary gained with the sponsoring employer in the same or a substantially comparable position — the theory being that the employer trained the beneficiary and cannot then demand that a U.S. applicant already possess what it was willing to teach.

Exceptions and workarounds:

• Experience gained in a position that is not substantially comparable — a different job, more than 50% different in duties — may be counted.
• Where it is no longer feasible to train a worker to qualify.
• Alternate requirements are permitted, and here the Matter of Francis Kellogg line requires that where alternate requirements are stated, the application must indicate that "any suitable combination of education, training, or experience is acceptable" — the so-called Kellogg language. Failing to include it where required is a recurring cause of denial.

Practical drafting rules:

• Describe the job that exists, not the beneficiary's résumé. An application whose requirements mirror the beneficiary's unusual background is the archetype of a tailored job and it will be audited.
• Confirm consistency with prior job postings, offer letters, job descriptions, and any H-1B filings for the same position. Inconsistency is the most common audit finding.
• Avoid unnecessary requirements, which raise the wage, narrow the applicant pool in a way DOL views skeptically, and require business necessity documentation.
• Foreign language requirements demand specific justification and are examined closely.
• Document the analysis at the time, in a memorandum, so that an audit two years later does not depend on memory.

Recruitment

The employer must test the labor market before filing. The steps differ for professional and non-professional occupations, and the timing is exacting.

Mandatory steps for all occupations:

1. State Workforce Agency job order — placed through the SWA serving the area of intended employment, running for at least 30 days.
2. Two Sunday advertisements in a newspaper of general circulation in the area most likely to bring responses. For a job requiring experience and an advanced degree, a professional journal may substitute for one of the two.
3. Notice of filing — posted at the worksite for 10 consecutive business days, and published in any in-house media normally used to announce job openings.

Three additional steps required for professional occupations (those normally requiring a bachelor's degree or higher), chosen from ten options in § 656.17(e)(1)(ii):

• Job fairs; the employer's website; another job search website; on-campus recruiting; trade or professional organizations; private employment firms; an employee referral program with incentives; a campus placement office; local or ethnic newspapers; and radio or television advertisements.

Content requirements for advertisements. Each must name the employer, direct applicants to report or send résumés to the employer, provide a description of the vacancy specific enough to apprise U.S. workers of the job opportunity, indicate the geographic area of employment, and — critically — must not contain requirements exceeding those on the application, must not contain wage lower than the prevailing wage, and must not contain any statement discouraging U.S. workers from applying.

Timing rules that must be observed exactly:

• All recruitment must occur within the 180 days before filing.
• At least one of the two Sunday advertisements, and the notice of filing, must have been placed more than 30 days but less than 180 days before filing.
• The quiet period: the application may not be filed until at least 30 days after the last recruitment step, so that applicants who respond late are still considered.

Reviewing applicants. This is a legal obligation, not a formality:

• Review every résumé received, without regard to source.
• Reject only for lawful, job-related reasons tied to the stated minimum requirements.
• Interview where the résumé does not clearly establish disqualification. A candidate whose résumé is ambiguous must be contacted.
• Consider whether the applicant could acquire the missing skill during a reasonable period of on-the-job training, which the regulations require.
• Document each applicant, the date received, the disposition, and the specific reason.
• Do not apply preferences not stated in the application, screen for immigration status, or reject for reasons unrelated to the stated requirements.

If a qualified and available U.S. worker applies, the labor certification cannot be filed. That is the entire point of the exercise, and employers who treat recruitment as theater discover the problem in an audit, in a whistleblower complaint, or in a False Claims Act or fraud investigation.

The recruitment report, signed by the employer, must summarize the recruitment steps, the number of applicants, and the lawful job-related reasons for rejecting each. It is not filed with the application but must be retained and produced on audit. Retain the résumés themselves as well.

Layoffs. If the employer laid off U.S. workers in the occupation or in a related occupation in the area within six months before filing, it must document that it notified and considered the laid-off workers. This is a strict requirement and it catches employers who conducted a reduction in force in an unrelated department.

Filing the PERM application

Form ETA-9089, filed electronically through the Department of Labor's case management system. Nothing is filed with it — no résumés, no advertisements, no recruitment report. The employer attests to the facts and retains the documentation for five years.

Processing. Times vary substantially with DOL's queue. Historically applications have taken from several months to well over a year, and there is no premium processing.

Three outcomes:

Certification. The application is approved and is valid for 180 days, within which the I-140 must be filed.

Audit. DOL requests the supporting documentation — the recruitment report, the advertisements, the notice of filing, the résumés, the business necessity documentation, and any requested items. Audits are random in some cases and triggered in others, by factors including a beneficiary-employer familial or ownership relationship, unusual requirements, foreign language requirements, layoffs, and a small employer with few employees. The response deadline is short and is not extended; assemble the audit file at the time of filing, not when the audit arrives.

Denial. Grounds include recruitment defects, requirements not justified, inconsistencies, and rejection of an apparently qualified U.S. applicant. Options are a request for reconsideration to the Certifying Officer, an appeal to the Board of Alien Labor Certification Appeals (BALCA), or refiling — the last being frequently the fastest path where the defect is curable.

Supervised recruitment. Where DOL doubts the good faith of the labor market test, it may order recruitment conducted under its direction, with DOL approving the advertisement text, receiving the résumés, and directing the process. It adds many months and is a serious development.

Form I-140 and the priority date

Filed by the employer with USCIS after certification (or immediately, in the no-PERM categories).

What it establishes:

• The beneficiary meets the requirements stated in the labor certification, as of the priority date. Evidence: degrees with credential evaluations for foreign education, and experience letters from prior employers on letterhead, signed, describing the dates, title, and duties in enough detail to match the requirements. Experience letters are the most common cause of a request for evidence and the hardest documents to obtain years after the fact — collect them at the time of hire.
• The employer's ability to pay the proffered wage from the priority date until permanent residence. Evidence: annual reports, federal tax returns, or audited financial statements showing net income or net current assets equal to or exceeding the proffered wage; or, if the beneficiary is already employed, evidence of wages actually paid. For employers with 100 or more employees, a financial officer's statement may suffice.

The priority date is the date the PERM was filed (or the I-140, in no-PERM categories). It is the beneficiary's place in the queue and it is portable to a later petition in most circumstances, including one filed by a different employer — which is why an approved I-140 is valuable even if the job changes.

Premium processing is available for most employment-based I-140s, producing adjudication within a defined period for an additional fee.

Priority date retrogression. The Visa Bulletin, published monthly, shows the priority dates currently eligible to proceed, by category and by country of chargeability. Annual limits and per-country caps mean that nationals of countries with high demand — India and China in particular — face waits that in some categories have extended well beyond a decade. Dates can retrogress, moving backward. Plan around this reality: it affects retention, it affects the beneficiary's family (children may age out, subject to the Child Status Protection Act's calculation), and it affects the employer's nonimmigrant strategy.

The final step

Adjustment of status — Form I-485, filed in the United States when a visa number is available under the Bulletin's applicable chart. Filing permits concurrent applications for an employment authorization document and advance parole, which together give the beneficiary and dependents flexibility that H-1B status alone does not.

Consular processing — through the National Visa Center and a U.S. consulate abroad. Often faster where the beneficiary is outside the United States, and it forecloses the EAD/advance parole benefits.

AC21 portability. 8 U.S.C. § 1154(j) permits a beneficiary whose I-485 has been pending 180 days or more to change employers, provided the new position is in the same or a similar occupational classification. The I-140 remains valid. This is the provision that gives long-waiting beneficiaries mobility, and it requires a supplement documenting the new offer.

H-1B extensions beyond six years. The American Competitiveness in the Twenty-First Century Act permits extensions in one-year increments where a labor certification or I-140 was filed at least 365 days earlier, and in three-year increments where an I-140 is approved but a visa number is unavailable due to per-country limits. These provisions are what make a decade-long wait survivable, and they should be calendared from the beginning.

Employer obligations and risks

Costs. The Department of Labor requires that the employer pay the costs of the labor certification, including attorney's fees attributable to it and all advertising costs. The beneficiary may not pay or reimburse them. Costs of the I-140 and the I-485 may be allocated differently, and the I-485 is the beneficiary's application. Document who paid what.

No contingent obligations. The employer may not require the beneficiary to reimburse PERM costs, may not condition sponsorship on a repayment agreement covering those costs, and should have any retention agreement reviewed for this issue.

A bona fide job opportunity. The position must be genuinely available to U.S. workers, and it must be a real, full-time, permanent position that the employer intends to fill at the stated terms. Positions created for the beneficiary, or that exist only on paper, are fraud.

Familial and ownership relationships. Where the beneficiary is related to the owner or is an owner, DOL applies heightened scrutiny under the Modular Container Systems factors and audits are near-certain. Sponsorship is not prohibited, but the employer must show the opportunity was clearly open, that the beneficiary did not influence the requirements or the hiring decision, and that someone independent evaluated the applicants.

Worksite issues. The area of intended employment drives the prevailing wage and the recruitment location. For a position with multiple worksites, roving employees, or remote work, identify the correct worksite — generally the employer's headquarters where the employee reports, or the location from which assignments are directed — and consider whether additional recruitment or a different wage applies. Remote work has made this materially more complicated, and DOL guidance has evolved.

Layoffs after filing in the same occupation and area can undermine a pending application and raise questions about the bona fides of the opportunity.

Retention. Keep the full audit file for five years from the filing date: the PWD, all advertisements with proof of placement and dates, the SWA job order, the posted notice with dates and a photograph, all résumés, the applicant log, the recruitment report, business necessity documentation, and the requirements memorandum.

Enforcement. DOL may debar an employer from the program for substantial failures, and misrepresentations can support criminal exposure under 18 U.S.C. § 1001 and civil exposure under the False Claims Act. The most serious cases involve employers who ran sham recruitment, rejected qualified U.S. applicants for pretextual reasons, or charged the beneficiary the costs.

Managing the timeline

A realistic schedule for an EB-2 or EB-3 with PERM, assuming no retrogression:

Total, best case: roughly two years. For an oversubscribed country, add the queue.

What employers should do with that information:

• Start early. Begin the process well before the beneficiary's nonimmigrant status becomes constraining. For an H-1B holder, the practical trigger is the fifth year, because the 365-day rule for extensions requires a filing a year before the sixth year ends.
• Track the H-1B clock and the AC21 milestones for every sponsored employee, centrally.
• Communicate honestly with the employee about the timeline. Most attrition in this population comes from employees who were told "we're working on it" and heard nothing for two years.
• Budget for the costs and for the possibility of an audit or a refiling.
• Have a policy — who is eligible for sponsorship, at what point in tenure, in what categories, and what happens if the employee leaves.

Alternatives worth evaluating first

Before committing to PERM, evaluate whether the beneficiary qualifies for a category that avoids it:

• EB-1A for someone with genuine acclaim — publications, citations, awards, media coverage, judging, original contributions.
• EB-1B for an academic researcher with international recognition.
• EB-1C for a manager transferred from a foreign affiliate, which is often the cleanest path for a multinational.
• EB-2 NIW for a researcher, entrepreneur, or professional whose work has national importance — a category that has expanded considerably and that self-petitions, giving the beneficiary independence from the employer.
• Cross-chargeability to a spouse's country of birth, which can move a beneficiary out of an oversubscribed queue entirely and is frequently overlooked.
• Concurrent filing of I-140 and I-485 where a visa number is immediately available.

The evaluation costs a few hours and can save two years. Do it at the outset, with counsel, and document the reasoning.

A closing note on how this feels

For the employee, this process is a decade of their life administered through forms, with a status that depends on continued employment, a spouse's work authorization that may or may not exist, children who may age out, and a queue position determined by their country of birth. For the employer, it is a compliance obligation with real costs and real risk.

Both perspectives are legitimate, and the practical advice that serves both is the same: start early, document everything at the time, tell the employee the truth about the timeline, and get the requirements analysis right at the beginning. Nearly every failure in this area — the denial, the audit, the refiling, the employee who leaves in year four — traces back to one of those four things.

The employee's parallel concerns

An employer running this process should understand what the beneficiary is managing, because it drives retention decisions and because the employer's choices affect it.

Maintaining status throughout. Permanent residence takes years, and the beneficiary must remain in valid nonimmigrant status the entire time or must be eligible to adjust despite a gap. An H-1B holder must have extensions filed timely; an L-1 holder faces a hard maximum (five or seven years by category) with no AC21 extension available, which makes the EB-1C route and its faster timeline important for L-1A holders; and a person on an F-1 with optional practical training has a defined runway.

Dependent work authorization. An H-4 spouse may obtain an EAD only where the principal has an approved I-140 or an AC21-based extension — so the I-140 approval is a household economic event, not merely a procedural one. L-2 spouses have work authorization incident to status. Other dependent categories generally do not.

Children aging out. A child who turns 21 loses derivative eligibility. The Child Status Protection Act provides a calculation subtracting the time the I-140 was pending from the child's age at visa availability, and the child must "seek to acquire" permanent residence within one year of availability. For a family in a long queue this is the single highest-stakes issue, and it should be modeled explicitly with dates rather than assumed.

International travel. Advance parole permits travel while an I-485 is pending; H-1B and L-1 holders may travel on their underlying status without abandoning the adjustment. Travel during a pending I-485 without either is an abandonment.

Job changes and promotions. Before the 180-day AC21 window, a change in employer restarts the process. After it, a change to a same-or-similar occupation preserves it. A promotion can be a problem: the labor certification describes a specific position, and moving the beneficiary into a materially different role before adjustment can undermine the petition. Employers frequently promote a sponsored employee and create an issue nobody flagged. Build a checkpoint into the promotion process.

The offer must remain valid. The employer must intend to employ the beneficiary in the certified position on the certified terms at the time permanent residence is granted. A confirmation letter is routinely requested late in the process.

Building an internal program

Employers sponsoring more than a handful of people should run this as a program rather than case by case.

A written sponsorship policy answering: who is eligible (by role, level, or tenure), when the process begins, which categories the company will pursue, what costs the company pays, whether any repayment obligation applies to costs the company may lawfully allocate, and what happens on resignation or termination mid-process. Publish it. The absence of a policy produces inconsistency, and inconsistency in immigration sponsorship is both a morale problem and a discrimination risk.

A single tracker containing, for each sponsored employee: current status and expiration, the H-1B six-year date, the 365-day AC21 milestone, the PWD request and issuance dates, recruitment dates, the PERM filing and certification dates, the I-140 filing and approval dates, the priority date, the visa category and chargeability country, and the I-485 status. Review it monthly.

Calendar the hard deadlines that have no cure: the 180-day validity of a certified PERM, the audit response deadline, the H-1B six-year limit, and the 365-day filing requirement for one-year extensions.

Coordinate with HR processes. Reductions in force, promotions, transfers, remote work approvals, and title changes each interact with a pending sponsorship. The simplest control is a rule that any change in status, title, location, or compensation for a sponsored employee routes through immigration counsel before it is effected.

Collect experience letters at hire, from every employee the company might eventually sponsor. Obtaining a letter from a prior employer six years later, after the supervisor has left and the company has been acquired, is the single most avoidable delay in the entire process.

Anticipate the audit. Assemble the complete audit file at filing and store it where it can be retrieved in a day. An audit arriving twenty months after filing, at a company that has changed HR systems and lost the advertisement tear sheets, is how a certifiable case becomes a denial.

Budget realistically. Government fees, advertising, prevailing wage, counsel, and — for a meaningful percentage of cases — an audit response or a refiling. An employer that budgeted only for the best case will be making a bad decision at the worst moment.

Frequently asked questions

Can the employee pay the legal fees to speed things up? No, not for the labor certification. Department of Labor rules place the costs of the labor certification — including attorney's fees attributable to it and all advertising — on the employer, and reimbursement arrangements covering those costs are prohibited. Costs of the I-140 and the beneficiary's own I-485 may be allocated differently, and many employers pay those as well.

Can we require the employee to stay for two years after the green card? A retention agreement is a contract question governed by state law, and enforceability varies. What an employer may not do is condition sponsorship on repayment of the labor certification costs. Any retention arrangement should be reviewed for that issue and for whether the state enforces such agreements at all.

What happens if the employee resigns during the process? The PERM and I-140 are the employer's; the employer may withdraw the petition. If the I-140 has been approved for at least 180 days, it generally remains valid for priority date retention and for AC21 extension purposes even after withdrawal, subject to revocation for fraud or material misrepresentation. The beneficiary keeps the priority date for a future petition.

Can we sponsor someone who is currently outside the United States? Yes. The labor certification does not require that the beneficiary be in the country, and the process concludes through consular processing.

Does a remote employee change the analysis? Yes, materially. The area of intended employment determines the prevailing wage and the recruitment location, and agency guidance on remote positions has evolved. Identify the worksite carefully, document the reasoning, and expect scrutiny.

What if we cannot find the newspaper tear sheets? Obtain affidavits of publication at the time of placement, and retain a copy of the tear sheet plus the invoice. Reconstructing proof of a two-year-old advertisement from a publisher that has since changed hands is a genuine problem, and it is entirely preventable.

Is a national interest waiver realistic for an ordinary professional? Sometimes. The Dhanasar framework does not require extraordinary ability, and petitions have succeeded for entrepreneurs, engineers working on infrastructure or energy problems, healthcare professionals in shortage areas, and researchers with a demonstrable record. It requires real evidence of national importance and of the beneficiary's position to advance the work, and adjudication has become more demanding. It is worth evaluating in every case precisely because it eliminates the labor certification entirely.

Primary authority

PERM is a regulation-driven process, and the regulation is unusually specific about recruitment.

• 8 U.S.C. § 1182(a)(5)(A) — the labor certification requirement, and the two findings the Department of Labor must make.
• 8 U.S.C. § 1153(b)(2) and § 1153(b)(3) — the EB-2 and EB-3 preference categories, including the national interest waiver in § 1153(b)(2)(B).
• 20 C.F.R. Part 656 — the PERM regulations: the prevailing wage process in § 656.40, recruitment requirements in § 656.17(e), the recruitment report in § 656.17(g), business necessity for restrictive requirements in § 656.17(h), layoff obligations in § 656.17(k), and audits and supervised recruitment in § 656.20 and § 656.21.
• 20 C.F.R. § 656.10(d) — the notice of filing, and § 656.30 for the 180-day validity period of an approved certification.
• 20 C.F.R. § 656.24(b) — the standard the certifying officer applies, and § 656.26 for review by the Board of Alien Labor Certification Appeals.
• 8 C.F.R. § 204.5 — the Form I-140 immigrant petition, including the ability to pay requirement in § 204.5(g)(2) and priority date retention in § 204.5(e).
• 8 U.S.C. § 1154(j) and 8 C.F.R. § 245.25 — AC21 portability after 180 days with an adjustment application pending.
• 8 C.F.R. § 245.1 and § 245.2 — adjustment of status, and 22 C.F.R. § 42.53 for consular processing.
• 8 U.S.C. § 1184(g)(4) and 8 C.F.R. § 214.2(h)(13)(iii)(D) — H-1B extensions beyond six years while a PERM or I-140 is pending.

Related articles

• Business Immigration Basics: H-1B, L-1, O-1, and the Employment-Based Green Card Path — the nonimmigrant statuses that precede this.
• Investor Visas: The E-2 Treaty Investor and the EB-5 Immigrant Investor Program — the investment-based alternatives.
• I-9 Compliance and Preparing for an ICE Audit — the parallel verification obligation.
• Hiring With Background Checks — the rest of the hiring process.
• Complying with Pay Transparency and Pay Equity Laws — posting requirements that interact with PERM advertisements.
• Managing a Multistate Remote Workforce — worksite determination for remote roles.
• Conducting a Reduction in Force: WARN, Selection Criteria, and Releases — the six-month layoff rule.
• Responding to a Government Subpoena or Civil Investigative Demand — if an audit becomes an investigation.
• Setting Up Payroll and Employment Compliance for a First Hire — onboarding a sponsored employee.
• Business Immigration Toolkit: Visas, PERM, and I-9 Compliance — the full roadmap.

This guide is provided for general informational purposes and does not constitute legal advice. Immigration processing times, forms, Visa Bulletin movement, and agency policy change frequently and without notice, and individual eligibility depends on facts specific to each case. Consult qualified immigration counsel before beginning a sponsorship.