Regions Financial Corporation · NYSE:RF
Regions Financial — Regions Paycor Form I-9 Webinar (July 2021)
44 slides from Regions Financial's conference presentation, July 2021
Slide 1: Form I-9: Keys to Compliance
Form I-9: Keys to Compliance Presented by Monica Weimar, SPHR, SHRM-CP HR Answerlink
Slide 2: Disclaimer
Disclaimer • This presentation has been prepared for informational purposes only and is not intended to provide – and should not be relied on for – legal advice. You should consult your own legal advisors to discuss specific questions you may have regarding immigration and I-9 issues.
Slide 3: Agenda
Agenda • Filing & Retention • The Form I-9 in-depth • Acceptable Documents • Penalties & Other Considerations • E-Verify • Audits • Q&A
Slide 4: Filing and Retention
Filing and Retention
Slide 5: Form I-9 File
Form I-9 File * Keep current employee and terminated employee files separately ¢ Alphabetized in a 3-ring binder
Slide 6: Retention period for Form I-9
• For as long as the employee works for you and the later of the following: 3 years after the hire date, or 1 year after termination • Easy math: • Employee’s Start Date + three years = date A • Employee’s Termination Date + one year = date B • Store their form I-9 until the later of the two dates
Slide 7: Destroying Form I-9 records
• Destroy once the retention period expires • Utilize a secure method • Document which I-9s have been destroyed • Do not destroy if undergoing an audit
Slide 8: Form I-9
Form I-9
Slide 9: Form I-9 editions
> Paycor Form I-9 4 * Current edition notes “07/17/17” at the bottom * Required for those hired on/after 9/18/17 * Old edition notes “03/08/2013” or “11/14/2016” at the bottom
Slide 10: New Form I-9 Overview
> Paycor New Form I-9 Overview 4 JERE * Creates a “smart” form * Improves form-filling functionality and accuracy + On-screen instructions + Retains requirement to print and store completed paper versions 10
Slide 11: Question: Wrong version of the I-9
Question: What if we’ve used the wrong version of the I-9 for employees hired on or after September 18th, 2017? Answer: You have two options: 1. The employer and employee complete the current version of the I-9 and staple it to the previous version. 2. Staple the outdated, but completed I-9 to the c
Slide 12: Who Completes Form I-9
Who Completes Form I-9 • Employer or employer representative • Section 2 must be completed by the individual that reviewed the IDs • Notary public acting as an employer representative • Discuss this with a notary ahead of time, as some cannot complete section 2 • No notary is required
Slide 13: Question: Do owners have to complete an I-9?
Question: Do owners of the company have to complete an I-9? Answer: All employees must complete an I-9. So, more than likely.
Slide 14: When is a Form I-9 NOT Required
When is a Form I-9 NOT Required • Non-Employees such as volunteers, unpaid interns, and independent contractors • Employees: • Hired before 11/6/1986 • Hired for casual domestic work in a private home • Providing labor to you who are employed by a contractor providing contract services (e.g., employ
Slide 15: Section 1: Employee's Responsibility
Section 1: Employee’s Responsibility
Slide 16: Section 2, Part I: Employer's Responsibility
Section 2, Part I: Employer’s Responsibility
Slide 17: Question: Photocopied documents and Section 2
Question: If we photocopy documents and send them to HR with the I-9, can the HR person at our company fill in Section 2? Answer: No, the same company representative that reviews the employee’s documents must fully complete Section 2, even if photocopies are made.
Slide 18: Section 2, Part II: Certification
Section 2, Part II: Certification
Slide 19: Section 3: Reverification and Rehires
Section 3: Reverification and Rehires
Slide 20: Question: New I-9 when rehiring an employee
Question: Do I need a new I-9 when I rehire an employee? Answer: You have two options: 1. You may complete a new I-9 for the rehired employee. or, 2. If the rehire is within 3 years of the date of the initial I- 9, you can review the original I-9 and complete Section 3, the Reverification and Rehire
Slide 21: Question: New I-9 after legal name change
Question: Do I need a new I-9 when an employee legally changes their name? Answer: Completing a new I-9 is not permissible. Updating the original I-9 is recommend, but not required.
Slide 22: Acceptable Documents
Acceptable Documents
Slide 23: List of Acceptable Documents
List of Acceptable Employees must present: one ID from Documents List A; OR one ID from List B and List C
Slide 24: List A of Acceptable Documents
List A of Acceptable Documents
Slide 25: Lists B & C of Acceptable Documents
Lists B & C of Acceptable Documents
Slide 26: List of Acceptable Documents
List of Acceptable Documents • Documents must be unexpired • Documents must be presented within 3 business days of hire • Photocopied documents are not acceptable • Receipts in lieu of IDs • Accept documents that reasonably appear to be genuine and relate to the person presenting them
Slide 27: Question: I-9 for a remote employee
Question: What should I do about an I-9 for a remote employee? Answer: There isn’t much wiggle room here, as the documents must be in-hand of the company representative who completes Section 2, and in the presence of the new employee.
Slide 28: Document Type and Issuing Authority
Document Type Issuing Authority U.S. Passport or Passport Card U.S. Department of State Permanent Resident Card U.S. Citizenship and Immigration Services (USCIS) Employment Authorization Card U.S. Citizenship and Immigration Services (USCIS) Driver’s License or State-Issued ID Any state, territory,
Slide 29: Question: Updating documents when they expire
Question: Once the I-9 is completed, do the documents have to be updated when they expire? Answers: For U.S. Citizens, noncitizen nationals and lawful permanent residents, No. If an individual’s work authorization expires, yes.
Slide 30: Question: Social Security Card not valid for employment
Question: What if an individual’s Social Security Card states “Not Valid for Employment” or “Valid for Work only with DHS Authorization”? Answer: A card with either of these statement is not valid for employment for acceptable for completion of the I-9. These cards may be used with time limited work
Slide 31: Penalties and Other Considerations
Penalties and Other Considerations
Slide 32: Employer Penalties
32 * Civil penalties and civil document fraud * Criminal penalties * Unlawful discrimination claim ween eee ee
Slide 33: Discrimination based on citizenship or immigration status
• It is illegal to discriminate based upon citizenship or immigration status • Laws prohibit employers from hiring only U.S. citizen or lawful permanent residents • Employers may not require “proof” prior to an accepted job offer • Choice of document
Slide 34: Acceptable employment application questions
• Acceptable employment application questions: • “Are you authorized to work lawfully in the United States for [Company Name]?” • “Will you now or in the future require [Company Name] to commence (“sponsor”) an immigration case in order to employ you (for example, H-1B or other employment- based imm
Slide 35: E-Verify
E-Verify
Slide 36: E-Verify Requirements
E-Verify Requirements • Requires copies of documents provided for the I-9 and a social security number • Optional for most U.S. employers • Required by federal or state law: • Federal contractors and subcontractors if the contractor contains the Federal Acquisition Regulation E-Verify clause • Requi
Slide 37: E-Verify Requirements
E-Verify Requirements If you participate in E-Verify (voluntarily or based on required use): • Newly hired employees must provide a Social Security Number • Any List B document must contain a photograph • Certain documents must be photocopied for E-Verify photo matching (U.S. Passport or passport ca
Slide 38: Audits
Audits
Slide 39: Conducting an Internal I-9 Audit
Conducting an Internal I-9 Audit * Why audit « When to audit * What is generally found in an audit 39
Slide 40: Internal I-9 Audit Steps
Internal I-9 Audit Steps Organize documents Determine priorities Reach out to each employee without an I-9 or with an incomplete I-9 Corrections Terminated employees Recording the audit 40
Slide 41: Question: Having all employees refill the form
Question: If we think the I-9 isn’t properly filled out, can we have all employees fill out the form again? Answer: No, you need to conduct an audit to determine which documents are missing or sections are incomplete.
Slide 42: Question: Correcting a Section 1 error
Question: If an employee makes an error in Section 1 that I catch later, is it acceptable for me to correct it and initial/date? Answer: No, you must ask the employee to correct an error/omission in Section 1 of the Form.
Slide 43: Q&A
Q&A
Slide 44: Monica Weimar
SPHR, SHRM-CP | HR Consultant HR Answerlink Monica has held roles as an HR Generalist and Payroll and Benefits manager at a large ski resort, providing HR guidance to more than 500 Monica Weimar employees. She also has HR experience in the healthcare field and the non-profit world. Monica holds a Ba
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