Form I-9 Compliance in Mergers and Acquisitions

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Last Updated: July 2026

A merger, acquisition, corporate reorganization, or sale of assets may transfer more than employees. It may also transfer defective Forms I-9, missed reverifications, unreliable electronic records, E-Verify problems, and potential civil liability.

The proper Form I-9 treatment depends substantially on the transaction structure and identity of the employer after closing.

In a stock or equity purchase, the employing legal entity often remains unchanged. New Forms I-9 generally are not required solely because ownership changed. The buyer, however, acquires the entity together with its existing records and potential compliance exposure.

In an asset purchase, employees may move to a different employing entity. The buyer may be able to treat the acquired workforce as new hires and complete new Forms I-9 or treat the employees as continuing in uninterrupted employment and obtain the seller’s existing records.

Form I-9 due diligence should begin early enough to affect the transaction documents, closing procedures, system migration, workforce-integration plan, and allocation of potential liability.

Form I-9 Treatment by Transaction Structure

Transaction Structure	Usual Form I-9 Consideration
Stock or equity purchase	The employing entity generally remains the same, so existing Forms I-9 ordinarily continue
Asset purchase with employees moving to a new employer	The buyer may treat acquired employees as new hires or, when permitted, as continuing employees
Statutory merger	The result depends on the surviving entity, workforce continuity, and transfer of records
Internal reorganization	Existing forms may continue if employees remain continuously employed by a related or reorganized employer and the records are maintained
Purchase involving only assets and no employees	The buyer generally has no acquired workforce requiring Form I-9 treatment
Transaction involving staffing-company workers	The buyer should evaluate the vendor relationship and should not assume the workers become its employees

Important Notice

The transaction label does not always determine the Form I-9 result.

The parties should identify:

The legal employer before closing.
The legal employer after closing.
Whether the employee relationship continues without interruption.
Whether employees will receive new offers.
Whether payroll will move to another entity.
Whether the predecessor’s Forms I-9 will be transferred.
Whether the buyer will accept responsibility for inherited records.

The analysis should occur before the parties communicate a Form I-9 process to employees.

Stock and Equity Purchases

In a stock or equity purchase, ownership of the employing company changes, but the employing legal entity often remains the same.

Because the employer generally remains unchanged:

Employees ordinarily continue working for the same entity.
Existing hire dates remain relevant.
New Forms I-9 generally are not required solely because ownership changed.
Existing reverification obligations continue.
The company retains its existing E-Verify obligations.
The buyer acquires the entity’s Forms I-9 and potential liabilities.

A stock buyer should not assume that Form I-9 due diligence is unnecessary. The acquired company may have:

Missing Forms I-9.
Substantive or uncorrected errors.
Overdue reverifications.
Knowing-employment concerns.
Improper E-Verify practices.
Unreliable electronic signatures.
Missing or disabled audit trails.
Pending government inspections.
Immigration-related discrimination claims.
Unresolved problems inherited from earlier acquisitions.

Completing new Forms I-9 for the entire existing workforce is generally not required merely because ownership changes. Any decision to undertake a broader re-verification process should have a legally appropriate purpose and should be implemented consistently.

Asset Purchases

In an asset purchase, employees commonly leave the seller and begin working for the buyer or another acquiring entity.

The buyer generally has two potential approaches.

Option 1: Treat Acquired Employees as New Hires

The buyer may treat acquired employees as newly hired employees and complete a new Form I-9 for each acquired employee.

USCIS directs employers selecting this approach to apply it to all acquired employees within the selected workforce, without regard to actual or perceived citizenship status or national origin.

The effective date of the asset acquisition generally becomes the employee’s first day of employment with the buyer for Form I-9 purposes.

This approach may:

Establish a uniform set of records under the buyer’s procedures.
Reduce future reliance on missing or defective seller records.
Place employees into the buyer’s Form I-9 system.
Establish a centralized starting point for reverification.
Avoid transferring records between incompatible electronic systems.

It also may require the buyer to:

Complete hundreds or thousands of forms within a short period.
Coordinate remote and absent employees.
Train authorized representatives.
Manage unfamiliar immigration documents and automatic extensions.
Create required E-Verify cases.
Conduct substantial post-closing quality control.

Completing new Forms I-9 may reduce the buyer’s future reliance on defective seller records. It does not necessarily eliminate successor liability, contractual exposure, or government claims involving pre-closing conduct.

Option 2: Treat Employees as Continuing in Employment

Under 8 C.F.R. § 274a.2(b)(1)(viii), continuing employment may include an employer that continues to employ some or all of a previous employer’s workforce following a sale of assets.

If the employees qualify as continuing in employment, the buyer may obtain and maintain the seller’s Forms I-9 instead of completing new forms.

The buyer should recognize that it may become responsible for errors and omissions on those forms.

Before selecting this option, the buyer should determine:

Whether a Form I-9 exists for each acquired employee.
Whether the forms are complete and readable.
Whether required reverifications occurred.
Whether electronic signatures can be authenticated.
Whether complete audit trails exist.
Whether the seller can transfer the complete records.
Whether records can be produced within an ICE inspection deadline.
Whether the seller has pending government matters.
Whether the buyer can integrate the records into its retention system.

Mergers and Corporate Reorganizations

A merger or reorganization may involve a surviving entity, a newly formed entity, or transfers among related entities.

Continuing employment may apply when an employee continues working for a related, successor, or reorganized employer and the employer obtains and maintains the previous employer’s Forms I-9.

The parties should document:

The entities involved.
The surviving employer.
The effective date.
Workforce continuity.
Transfer of Forms I-9.
Treatment of original hire dates.
Continuing reverification obligations.
E-Verify account changes.
Treatment of employer-sponsored workers.

Successor Liability for Defective Forms I-9

The OCAHO decision in United States v. Nevada Lifestyles, Inc., 3 OCAHO 518, illustrates the risk of relying on a predecessor’s records.

The successor continued employing the acquired workforce and relied on the predecessor’s Forms I-9. OCAHO concluded that the successor could be held responsible when the predecessor’s forms were missing or defective.

The continuing-employment rule may reduce redundant paperwork. It does not necessarily provide immunity from Form I-9 liability.

Successor liability remains fact-specific and may depend on the transaction, workforce continuity, corporate relationships, governing law, and violations alleged.

Form I-9 Due Diligence

Form I-9 due diligence should determine whether the buyer can safely rely on the seller’s records and what corrective work may be required.

A practical review generally includes:

Identifying the affected employing entities.
Reconciling the workforce census against the Form I-9 inventory.
Reviewing policies, training, and actual practices.
Reviewing all or a neutral sample of Forms I-9.
Reviewing reverification.
Testing electronic systems and audit trails.
Reviewing E-Verify.
Identifying government investigations and prior violations.
Reviewing staffing and contractor arrangements.
Identifying employer-sponsored workers.
Estimating corrective work and potential exposure.
Addressing findings in the transaction documents.

Identify the Employing Entities

The buyer should identify every legal entity employing workers affected by the transaction.

This may include:

Operating companies.
Subsidiaries.
Related entities.
Professional employer organizations.
Payroll entities.
Joint ventures.
Staffing companies.
Entities using a shared HR department.

The legal employer reflected in payroll records may not match the entity identified on Form I-9.

The buyer should understand:

Which entity hired each employee.
Which entity signed Section 2.
Whether employees transferred among affiliates.
Whether previous transfers were documented.
Whether the related Forms I-9 followed the employees.
Whether the transaction changes the employing entity.

Reconcile the Workforce and Form I-9 Inventory

The seller should provide an employee census identifying:

Employee name or unique identifier.
Original hire date.
Employing entity.
Work location.
Employment status.
Termination date, when applicable.
Rehire date, when applicable.
Whether a Form I-9 is available.
Whether the record is paper or electronic.
Whether reverification is required.
The next reverification date.
Whether an E-Verify case was created.

The Form I-9 inventory should be compared against payroll, benefits, HR, tax, and timekeeping records.

Common problems include:

Active employees missing from the Form I-9 inventory.
Multiple unexplained forms for one employee.
Forms filed under incorrect or former names.
Employees listed under the wrong entity.
Employees transferred without their records.
Former employees incorrectly listed as active.
Independent contractors who may have been misclassified.
Staffing workers incorrectly treated as direct employees.

Review Policies and Actual Practices

The buyer should request the seller’s written Form I-9 and E-Verify policies.

The review should determine:

Who completes Section 2.
Who examines employee documents.
What training those individuals receive.
Whether authorized representatives are used.
Whether documents are physically or remotely examined.
Whether document copies are retained.
How receipts are handled.
How corrections are made.
How reverification is tracked.
How E-Verify mismatches are handled.
Whether internal audits occurred.
Whether local practices differ from the central policy.

A compliant written policy may provide limited protection if the employer’s actual practices differ.

Full Review or Sample Audit

A full review may be appropriate when:

The workforce is reasonably sized.
The buyer intends to rely on inherited forms.
The inventory does not reconcile with payroll.
A preliminary sample shows widespread errors.
Reverifications appear overdue.
ICE has inspected or contacted the seller.
Electronic audit trails are missing.
The seller lacks a reliable compliance process.

A sample may provide a preliminary risk assessment when the workforce is large or the transaction timeline is limited.

The sample should use neutral criteria and may include different:

Locations.
Employing entities.
Hiring periods.
HR representatives.
Paper and electronic systems.
Remote and onsite onboarding methods.
Acquired and organically hired workforces.

A sample may identify a problem. It cannot establish that every unreviewed form is compliant.

Review the Forms I-9

The review should determine whether:

A form exists for each covered employee.
The appropriate edition was used.
Section 1 was completed and signed timely.
The employee completed the required attestation.
Preparer or translator information was included when required.
Section 2 was completed and signed timely.
The employee’s first day of employment was entered correctly.
Acceptable document information was recorded.
The document combination was permissible.
Supplement B was completed when required.
Corrections are transparent and dated.
The form was not backdated.
Retained document copies are consistent with policy.
Remote examination satisfied the applicable requirements.

The review should apply the Form I-9 requirements that existed when the form was completed.

Review Reverification

The buyer should obtain a report of employees with temporary employment authorization.

The review should identify:

Upcoming reverification dates.
Overdue reverifications.
Automatic extensions.
Federal Register extensions.
Employer-specific authorization.
Pending immigration filings.
Employees incorrectly scheduled for reverification.

The buyer generally should not reverify U.S. citizens, noncitizen nationals, lawful permanent residents who presented Permanent Resident Cards, or List B identity documents.

An expired document does not always mean that employment authorization expired.

Test Electronic Form I-9 Systems

A software vendor’s marketing or contractual assurances do not relieve the employer of responsibility.

Federal guidance states that using Form I-9 software does not guarantee compliance.

The seller should be able to produce:

Complete Forms I-9.
Supplements.
Authenticated signatures.
Document copies, if retained.
Remote-examination records.
Correction histories.
Complete audit trails.
User-access records.
Dates and reasons for changes.
Records in a readable and reproducible format.

The buyer should determine:

Whether audit trails were continuously enabled.
Who could change system settings.
Whether users could overwrite entries.
Whether original information remains available after correction.
Whether signatures can be authenticated.
Whether exports preserve metadata.
Whether the buyer can import the complete records.
Whether vendor consent is required.
Whether former employee records remain accessible.
Whether records can be produced within an ICE deadline.

A PDF image may not constitute the complete electronic record.

General-Purpose Storage Tools

A shared drive, cloud folder, or general-purpose Microsoft Office storage tool is not automatically noncompliant. It also is not automatically sufficient for electronic Form I-9 retention.

Under 8 C.F.R. § 274a.2(g), electronic systems must provide appropriate security, backup, recovery, and secure permanent records of relevant actions.

A file’s creation date or “last modified” date may not establish:

Who changed the record.
What changed.
What the previous version contained.
Why the change occurred.
Whether the signature can be authenticated.

The buyer should review the platform and its actual configuration.

Uploaded Document Images

An employee’s photograph or uploaded copy of a document does not, by itself, satisfy the document-examination requirement.

Under the standard procedure, the employer or authorized representative generally must physically examine the original documents.

A qualified employer using the DHS-authorized alternative procedure generally must:

Participate in E-Verify and remain in good standing.
Receive and retain clear document copies.
Examine the copies.
Conduct a live video interaction with the employee presenting the same documents.
Complete the required Form I-9 notation or checkbox.
Create an E-Verify case when required.
Use the procedure consistently at the applicable hiring site.

Software may facilitate document collection. It does not replace the required examination and attestation.

The Section 2 Signer

The person signing Section 2 attests to examining the employee’s documents.

A process in which one person examines or copies the documents and another person signs Section 2 may be defective if the signer did not perform the required examination.

Another HR employee may perform quality control or administrative work. That person should not sign an attestation concerning an examination they did not conduct.

From Our Experience

We have encountered several electronic practices that created significant Form I-9 concerns:

An HR representative intentionally disabled an audit trail because it was considered unnecessary or burdensome.
An employer used general-purpose Microsoft Office storage tools without understanding the electronic audit-trail requirements.
Software did not comply with applicable electronic Form I-9 requirements.
Software collected photographs of employee documents without ensuring that an employer representative examined the originals or completed a qualifying remote examination.
One person copied employee documents while another person completed and signed Section 2.
A software vendor instructed an employer to complete replacement Forms I-9 for its entire workforce solely to populate a new electronic database.

These situations demonstrate why due diligence should examine the complete workflow:

How the employee completes and signs Section 1.
Who examines the documents.
How the examination occurs.
Who completes and signs Section 2.
How corrections are recorded.
Whether signatures can be authenticated.
Whether audit trails were continuously enabled.
Whether records can be exported and produced.

Redoing Forms Solely for Software Migration

Adopting software does not, by itself, require an employer to complete new Forms I-9 for its existing workforce.

Joint ICE and Department of Justice guidance cautions that requiring existing employees to complete new forms without sufficient justification may create discrimination concerns.

Mass replacement may:

Create new completion errors.
Produce incorrect hire dates.
Lead HR to request unnecessary documents.
Disconnect replacement forms from original records.
Conceal correction histories.
Create duplicate records without explanation.
Fail to correct the underlying deficiencies.

A buyer that properly elects to treat acquired employees as new hires following an asset purchase presents a different situation.

Review E-Verify

The buyer should determine:

Which entities and hiring sites are enrolled.
Whether participation is voluntary or required.
Whether a federal contract contains the FAR E-Verify clause.
Whether cases were created timely.
Whether mismatches were handled properly.
Whether employees experienced prohibited adverse action.
Whether Final Nonconfirmations remain unresolved.
Whether required records were retained.
Whether the transaction requires account changes.

A voluntary participant generally should not create E-Verify cases for existing continuing employees merely because ownership changed. Different rules may apply to federal contractors and employers subject to state requirements.

Review Government Matters

The seller should disclose:

ICE Notices of Inspection.
Administrative subpoenas.
Notices of Discrepancies.
Notices of Suspect Documents.
Warning Notices.
Notices of Intent to Fine.
OCAHO proceedings.
Settlement agreements.
Government monitoring.
E-Verify compliance reviews.
Department of Justice investigations.
Search warrants and worksite raids.
Internal audits conducted in response to government action.

The buyer should review the underlying correspondence rather than rely solely on a statement that a matter was resolved.

Review Staffing and Contract Labor

The buyer should identify workers supplied through:

Staffing agencies.
Labor contractors.
Subcontractors.
Professional employer organizations.
Temporary-help companies.
Independent-contractor arrangements.

A customer generally should not demand Forms I-9 from another employer’s workers without a valid reason. It also should not ignore credible information that a contractor is knowingly supplying unauthorized labor.

Identify Employer-Sponsored Workers

Form I-9 continuity does not necessarily mean that employer-specific immigration authorization survives the transaction.

The buyer should identify employees in classifications such as:

H-1B.
H-2A or H-2B.
L-1.
E-1 or E-2.
TN.
O-1.
R-1.
Employees with pending permanent-residence sponsorship.

The transaction may affect the petitioning employer, worksite, job duties, wages, corporate relationships, treaty nationality, or other requirements.

These employees should be reviewed before closing.

Due-Diligence Red Flags

Potential red flags include:

The employee census does not match the Form I-9 inventory.
Large numbers of forms are missing.
Forms appear backdated.
Identical handwriting or signatures appear across forms.
Reverifications are overdue.
Audit trails were disabled.
Signatures cannot be authenticated.
The seller cannot export complete electronic records.
Employees uploaded photographs without a valid document examination.
A different person signed Section 2 than examined the documents.
Replacement forms contain incorrect hire dates.
E-Verify was used selectively.
Government notices were not disclosed.
Managers know about identity sharing.
Previous acquisitions occurred without transferring records.

A red flag may justify expanding the review, changing the integration strategy, or negotiating additional protection.

Addressing Form I-9 Risk in the Purchase Agreement

The purchase agreement may allocate financial responsibility between the parties. It generally cannot prevent the government from pursuing a legally responsible employer.

Representations and Warranties

Potential representations may address whether:

Required Forms I-9 exist.
Forms were completed and retained properly.
Required reverifications occurred.
Electronic signatures can be authenticated.
Audit trails were preserved.
Remote examination complied with DHS requirements.
E-Verify was used properly.
No knowing-employment issue is known.
Government investigations and notices were disclosed.
Internal audits and material findings were disclosed.
Staffing practices complied with applicable requirements.

A broad statement that the seller complied with all immigration laws may not provide enough detail.

Disclosure Schedules

The seller should consider disclosing:

Missing or materially defective forms.
Overdue reverifications.
Unresolved E-Verify cases.
Disabled audit trails.
Unauthenticated signatures.
Incomplete system exports.
Improper document-examination practices.
Internal-audit findings.
Government notices.
Discrimination complaints.
Known contractor concerns.

Pre-Closing Covenants

Potential covenants may require the seller to:

Continue ordinary Form I-9 compliance.
Complete required reverifications.
Preserve all records.
Avoid disabling audit trails.
Avoid deleting or backdating forms.
Notify the buyer of government contacts.
Obtain necessary vendor consent.
Complete agreed corrective action.
Cooperate with additional due diligence.

Closing Deliverables

Deliverables may include:

The final employee census.
Complete Forms I-9.
Supplements and reverifications.
Retained document copies.
Electronic signatures.
Audit trails.
Correction histories.
E-Verify records.
Government correspondence.
Internal-audit records.
Vendor agreements.
System exports.
Access instructions.
Immigration-sponsorship files.

The buyer should test the records before the seller’s access ends.

Indemnification, Escrows, and Holdbacks

Potentially covered losses may include:

Civil penalties.
Government-response costs.
Legal fees.
Correction costs.
Discrimination claims.
E-Verify matters.
Data-recovery and migration costs.
Losses resulting from inaccurate representations.

An escrow or holdback may be considered when exposure is difficult to estimate or a government matter remains unresolved.

Immigration counsel may identify the compliance risk, while transaction counsel should address the resulting business terms.

Closing and Post-Closing Integration

The buyer should have a written integration plan before closing.

The plan should identify:

The Form I-9 approach.
Responsible personnel.
Record-transfer procedures.
Electronic-system requirements.
Remote-employee procedures.
E-Verify responsibilities.
Reverification deadlines.
Employee communications.
Escalation procedures.
Post-closing quality control.

New-Hire Treatment Following an Asset Purchase

If the buyer treats acquired employees as new hires:

Section 1 generally must be completed no later than the employee’s first day with the buyer.
Section 2 generally must be completed within three business days.
The transaction effective date generally becomes the employee’s hire date.
Employees may choose acceptable documents.
The process should cover the entire selected acquired workforce.
E-Verify cases should be created when required.

USCIS permits advance completion after an employee receives and accepts an offer.

The buyer should prepare for remote employees, employees on leave, acceptable receipts, automatic extensions, language assistance, system outages, and unfamiliar documents.

Continuing-Employment Treatment

If the buyer relies on predecessor forms, the transfer should include:

Active employee Forms I-9.
Retained former employee forms.
Supplements.
Retained document copies.
Correction explanations.
Electronic signatures.
Audit trails.
E-Verify records.
Reverification reports.
Government correspondence.
Records inherited from previous acquisitions.

The buyer should document when and how the records were transferred.

Paper-Record Transfer

A paper transfer should include:

A final inventory.
Original hire dates.
Employing entities.
Termination dates.
Reverification dates.
All pages and supplements.
Retained document copies.
A chain-of-custody record.

Maintaining paper originals or backup copies may be safer when electronic conversion has not been validated.

Electronic-Record Transfer

The buyer should confirm that transferred records preserve:

The completed forms.
Supplements.
Electronic signatures.
Authentication records.
Audit trails.
Correction histories.
User identities.
Document copies.
E-Verify information.
Original employment dates.

The seller or vendor should retain a backup until the buyer confirms successful transfer.

Reverification After Closing

Reverification should continue without interruption.

The buyer should validate:

Upcoming deadlines.
Automatic extensions.
Federal Register extensions.
Employer-specific authorization.
Overdue reverifications.
Improper reminders for Permanent Resident Cards or List B documents.

The buyer should not assume that every expired document establishes expired authorization.

E-Verify After Closing

If acquired employees are treated as new hires and the buyer participates in E-Verify, the buyer generally should create cases after completing Form I-9.

If employees remain continuing employees, a voluntary participant generally should not create new E-Verify cases solely because the transaction occurred.

Federal contractors and employers subject to state requirements may have different obligations.

Post-Closing Quality Control

Shortly after closing, the buyer should determine:

Whether every employee is accounted for.
Whether required forms were completed.
Whether transferred records match the census.
Whether E-Verify cases were created when required.
Whether mismatches were handled correctly.
Whether audit trails functioned.
Whether authorized representatives followed the process.
Whether any employee experienced an improper document request.

A broader 30- to 90-day review may evaluate outstanding corrections, seller cooperation, electronic-system reliability, training, and whether an internal audit is warranted.

Common M&A Form I-9 Mistakes

Common mistakes include:

Treating every transaction structure the same.
Waiting until closing to select a strategy.
Assuming new forms eliminate historical liability.
Relying on seller records without review.
Completing new forms only for noncitizens.
Using the seller’s original hire date for asset-purchase new hires.
Redoing forms solely to populate software.
Relying on uploaded photographs without valid examination.
Separating the examiner from the Section 2 signer.
Using general storage without reviewing electronic controls.
Allowing audit trails to be disabled.
Destroying paper records before validating electronic copies.
Failing to transfer reverification deadlines.
Creating E-Verify cases improperly.
Ignoring employer-sponsored workers.
Failing to secure post-closing seller cooperation.

Frequently Asked Questions

Are new Forms I-9 required after a stock purchase?

Generally, not solely because ownership changed. The employing entity ordinarily remains the same and retains its existing records and liabilities.

Are new Forms I-9 required after an asset purchase?

Not always. The buyer may treat acquired employees as new hires or, when permitted, as continuing employees and retain the seller’s forms.

Can an asset buyer rely on the seller’s Forms I-9?

Potentially, but the buyer may become responsible for errors and omissions on those forms.

Does completing new Forms I-9 eliminate historical liability?

Not necessarily. New forms may establish post-closing compliance but do not automatically eliminate previous violations or successor liability.

Must new Forms I-9 be completed for all acquired employees?

When the buyer elects new-hire treatment, USCIS directs the employer to apply the process consistently to all acquired employees within the selected workforce.

Can the buyer begin before closing?

Yes. USCIS permits advance completion after the employee receives and accepts an offer.

What hire date should an asset buyer use?

The transaction’s effective date generally becomes the employee’s first day with the buyer when new-hire treatment is selected.

Is an electronic audit trail required?

Electronic retention rules require secure and permanent records of relevant actions. Employers should not treat audit trails as optional.

Is an uploaded photograph sufficient?

Not by itself. The employer must physically examine the original documents or comply with every requirement of the authorized alternative procedure.

Can one person examine documents while another signs Section 2?

This may be defective. The signer attests to having performed the document examination.

Should a voluntary E-Verify participant create cases for continuing employees?

Generally, no. Different rules may apply to federal contractors and employers subject to other requirements.

What if an ICE inspection is pending?

The parties should address control of the response, preservation, costs, employee notices, settlement authority, indemnification, and seller cooperation before closing.

Primary Authorities and Government Guidance

Related Employer Compliance Resources

Working with Myers Immigration Law

Form I-9 issues in mergers and acquisitions may affect due diligence, transaction terms, system migration, E-Verify, workforce integration, and continued employment authorization.

Myers Immigration Law assists buyers, sellers, employers, and transaction counsel with Form I-9 due diligence, internal audits, electronic-system reviews, government inspections, and post-closing compliance planning.

For case-specific questions or concerns, please contact Myers Immigration Law at (210) 640-7424 or info@myersimmigration.com.

This page provides general information and is not legal advice. E-Verify and Form I-9 requirements may depend on the employer’s location, enrollment type, contracts, workforce, hiring practices, and particular facts. Government guidance and applicable laws may change. Employers should review current government instructions and consider obtaining case-specific advice before acting on a mismatch, Final Nonconfirmation, federal-contractor obligation, government inquiry, or possible employment-authorization issue.