Notary Knowledge by Derrick Spruill

Corporate Onboarding: The High-Volume I-9 Rep - Money Making Monday

Derrick Spruill Season 10 Episode 485

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0:00 | 39:00

Ready to boost your weekly income with a steady stream of corporate work? In this episode, Eddie Montes Travis and Marylyn Lee Trotter explore how you can become a high-volume I-9 Representative for large businesses. Learn how to transition from occasional signings to consistent corporate onboarding assignments that keep your calendar full. • Corporate Partnerships: Finding and building relationships with large HR departments and staffing agencies to become their go-to local representative. • I-9 Compliance Mastery: Understanding the specific legal requirements and common errors to avoid when completing employment eligibility verification for new hires. • Volume Strategies: Organizing your schedule to handle multiple appointments in a single day at a central corporate office or local hub. • Revenue Growth: Calculating your potential earnings when moving into this specialized niche of the mobile service industry. Mastering the art of high-volume work is a game-changer for any mobile professional looking to scale their business quickly. Don't miss these practical tips on how to dominate the corporate onboarding market. Please make sure to subscribe and like the podcast!

Show Notes:
• Understanding the role of an I-9 authorized representative.
• How to find corporate clients needing onboarding help.
• Tips for managing high-volume paperwork efficiently.
• Legal basics of I-9 verification forms.

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Executive Producer Derrick Spruill
Writers Marylyn Lee Trotter and Eddie Montes Travis
Graphics & Illustrations by Eddie Montes Travis
Music by Thomas Bynum
This Show is Produced by Magnificent Workz
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SPEAKER_00

Need a blueprint to start your mobile notary business? Don't stumble through the premises. You need an outline for success. Introducing the mobile notary blueprint by Derek Sprugal. Build your thriving mobile business and protect yourself from costly mistakes with expert advice.com, Barnes and Noble Bookstore, Booksofmillion.com, Bookshop.org, Mobile Notary by DerekSprugle.com, or download from Kindle and build your successful notary business today.

SPEAKER_03

Imagine a new hire um logging into their very first day of work from their living room in Seattle.

SPEAKER_00

Right.

SPEAKER_03

And they have this absolute mountain of onboarding paperwork. But HR is like 3,000 miles away in New York.

SPEAKER_02

Exactly. Completely across the country.

SPEAKER_03

Yeah. So to get it done, the new hire's roommate just, you know, glances at their passport, scribbles some information on a federal immigration document, leaves a few boxes blank, and unknowingly creates a permanent $28,000 liability for a Fortune 500 company.

SPEAKER_02

It's terrifying. But welcome to Notary Knowledge.

SPEAKER_03

Aaron Powell We are Eddie in Marilyn, and we are coming to you with a really bold, direct mandate today.

SPEAKER_02

Absolutely. Because if you're listening to this, you are not a beginner. You are a savvy strategist. You're a high-level operator looking for that next highly lucrative, scalable vertical in the corporate compliance space.

SPEAKER_03

And our mission today is Razor Sharp. We are focusing entirely on corporate onboarding.

SPEAKER_02

Specifically, how you position yourself as a high-volume elite I-9 authorized representative for enterprise hiring.

SPEAKER_03

Because we're looking at this from a very experienced, high-level perspective. I mean, for those of you who followed our prior strategies on securing corpor vendor contracts, yeah.

SPEAKER_02

Consider this the master class application of those exact principles.

SPEAKER_03

Right. We are zeroing in on a massive compliance crisis that is currently literally keeping enterprise human resources directors awake at night.

SPEAKER_02

Oh, absolutely. The numbers behind this crisis are just staggering. By 2025, over 75% of workers will demand hybrid or remote work.

SPEAKER_03

75%? That's huge.

SPEAKER_02

It is a permanent structural shift in how the American economy operates. And it has collided violently with a federal law that requires physical in-person document inspection for every single new hire.

SPEAKER_03

Which is basically a geographical impossibility for HR now.

SPEAKER_02

Exactly. I mean, you have enterprise teams sitting in a skyscraper in Austin or Chicago, and they're trying to hire top engineering talent in, say, San Jose or Dallas.

SPEAKER_03

Right. And they are legally blocked from completing the onboarding process because they are thousands of miles away from the employees' physical identity and work authorization documents.

SPEAKER_02

Aaron Powell And the stakes for getting this wrong, they have never been higher.

SPEAKER_03

No. Because today we're going to expose the devastating March 2026 policy changes by U.S. immigration and customs enforcement.

SPEAKER_02

Which most people just know as ICE.

SPEAKER_03

Right, ICE. They have completely rewritten the rule book. They turned minor clerical errors that, you know, used to just get a warning into massive, uncorrectable, immediate fines.

SPEAKER_02

Aaron Powell, it sounds like an absolute regulatory nightmare for corporate America.

SPEAKER_03

It really does. But for you, the savvy strategist listening right now, it's the ultimate B2B opportunity.

SPEAKER_02

Oh, without a doubt, you're going to learn how to step into the gap as an elite compliance partner.

SPEAKER_03

Aaron Powell But to actually capitalize on this corporate onboarding niche, we have to start at the foundation. Like we need to understand the exact logistical nightmare that HR directors are dealing with.

SPEAKER_02

Right. So let's go back to the federal mandate itself.

SPEAKER_03

Where does this requirement actually originate?

SPEAKER_02

Aaron Powell Well, it stems from the Immigration Reform and Control Act of 1986. Right. It's often referred to as IRCA. And the core principle of IRCA was to basically shift the burden of immigration enforcement squarely onto the shoulders of American businesses.

SPEAKER_03

Wow. Okay. So the mandate is pretty simple in theory, right? Employers just cannot knowingly hire unauthorized workers.

SPEAKER_02

Exactly. And to ensource this, the federal government created the Form I-9, the Employment Eligibility Verification Document.

SPEAKER_03

Which applies to everyone, right?

SPEAKER_02

Every single U.S. employer and every single W-2 employee hired after November 6, 1986.

SPEAKER_03

Aaron Powell So it's universal, but I mean, what makes it a logistical nightmare today compared to back in 1986? Because b back then everyone just went into an office, shook hands, and handed their boss a driver's license.

SPEAKER_02

Yeah. And that is exactly the issue. The law was built for an analog in-person world. But the execution is governed by this ruthlessly strict timeline that really doesn't care if your workforce is remote.

SPEAKER_03

Ah, the timeline.

SPEAKER_02

Right. The employee must complete section one of the form on or before their very first day of employment.

SPEAKER_03

Okay, on or before day one.

SPEAKER_02

Yep. Then the employer must complete section two within three business days of the employee's start date. And that three-day window, it's non-negotiable.

SPEAKER_03

So if someone starts on a Monday, the employer has until Thursday to like look at the documents and sign the form?

SPEAKER_00

Correct.

SPEAKER_03

Which brings us right back to the remote work problem. I mean, if the HR manager is in Chicago and the new hire is in Seattle, HR cannot physically examine their original passport. Right. And the law strictly forbids just looking at a photocopy, right?

SPEAKER_02

Oh, absolutely. For decades, the law has strictly forbidden examining photocopies. The original physical document must be examined in the physical presence of the employee. Wow. So to solve this, the government created a workaround. We can call it the authorized representative loophole.

SPEAKER_03

Okay, I like the sound of that.

SPEAKER_02

Yeah. It is officially detailed in the USCIS M274 handbook for employers. Basically, the federal government allows an employer to designate an authorized representative to act as their agent.

SPEAKER_03

So a local proxy.

SPEAKER_02

Exactly. This representative meets the employee locally, physically examines the original documents, and then completes and signs section two on the employer's behalf.

SPEAKER_03

Okay, this is where it gets really interesting for the people listening, I think, because who is actually allowed to be this representative? Does it have to be like a lawyer or a federal agent?

SPEAKER_02

That is the wild part. According to the federal guidelines, almost anyone can serve in this capacity.

SPEAKER_03

Wait, anyone?

SPEAKER_02

Basically, yeah. A personnel officer, a foreman, an agent, a notary public acting in a non-official capacity, or even get this friend or family member of the new hire.

SPEAKER_03

Aaron Powell Wait, hold on. A friend or family member. So an HR director at a major corporation can just tell a new hire to have their college roommate verify their federal documents.

SPEAKER_02

Yes, it is technically legal under federal law.

SPEAKER_03

That sounds insane.

SPEAKER_02

It is. And it introduces the ultimate liability trap, which is the very reason our listeners are going to be able to sell their services at a massive premium.

SPEAKER_03

Okay, what's the catch?

SPEAKER_02

Here is the catch. The employer remains 100% legally and financially liable for any error the authorized representative makes.

SPEAKER_03

Oh, wow.

SPEAKER_02

Yeah. If the representative makes a mistake, the employer pays the fine. The roommate doesn't pay it, the massive corporation does.

SPEAKER_03

So this is what we see all the time in the corporate world, right? We call it the friends and family anti-patch. Exactly. To save money and time, HR tells the remote hire, hey, just have your roommate, your spouse, or your cousin look at your passport and sign section two. Right, which is just It sounds like they are essentially outsourcing their federal compliance liability to a totally untrained civilian. I mean it's like it's like handing the keys of a Formula One race car to a teenager who just got their learner's permit.

SPEAKER_02

Oh, that's a perfect analogy.

SPEAKER_03

Right. A crash isn't just possible, it's absolutely inevitable. But the massive corporation is the one paying the insurance premium when that car hits the wall.

SPEAKER_02

That is a brilliant way to frame it. Think about the mechanics of what is actually happening during that process. A roommate has zero training in immigration compliance.

SPEAKER_01

Right. None.

SPEAKER_02

They do not know how to spot fraudulent documents. They do not know the complex sequencing required in section two, like identifying the correct issuing authority or matching expiration dates perfectly.

SPEAKER_03

And when people don't understand a government form, what do they usually do?

SPEAKER_02

They panic, they leave fields blank, they use whiteout to fix mistakes, or they write the dates in the wrong format.

SPEAKER_03

It is a ticking time bomb just sitting in a filing cabinet somewhere.

SPEAKER_02

Oh, absolutely.

SPEAKER_03

Before we explain exactly how that bomb goes off, because the government recently changed how they penalized those mistakes, I want to remind you to take your professional development to the next level.

SPEAKER_02

Yes, definitely.

SPEAKER_03

If you are serious about becoming an elite compliance partner, you need to arm yourself with the right resources. Be sure to buy the notary knowledge books by Derek Spruel.

SPEAKER_02

They are fantastic.

SPEAKER_03

And visit the Notary Knowledge website for unparalleled resources and high-level training materials designed specifically for the savvy strategist. It's so true. Now let's explore why corporate HR is suddenly so desperate for professional authorized representatives instead of just relying on that friends and family method.

SPEAKER_02

Because things changed, right?

SPEAKER_03

Big time. Because the federal government just changed the rules of engagement and they did it very, very quietly. You are referring to the March 2026 ICE fact sheet overhaul. I am. To understand why this change is sending shock waves through corporate boardrooms, we really need to understand how ICE audits used to work. There was an old framework that gave employers a pretty comfortable safety net, wasn't there?

SPEAKER_02

Yes. For decades, audits were governed by a nineteen ninety-seven directive known as the Virtue Memorandum.

SPEAKER_03

Okay, the Virtue Memorandum.

SPEAKER_02

Right. Under that old framework, if immigration and customs enforcement audited your company, meaning they served you with a notice of inspection and demanded to see all your I-9s within three days, they would categorize any paperwork violations they found.

SPEAKER_03

Okay.

SPEAKER_02

If the errors were gained technical or procedural, the employer was given a 10 business day grace period to fix them before any fines were assessed.

SPEAKER_03

So it was essentially a get out of jail free card.

SPEAKER_02

Pretty much, yeah.

SPEAKER_03

If a roommate forgot to date a signature, ICE would point it out. And HR had ten days to track the employee down and say, hey, fill in the date, no harm, no foul.

SPEAKER_02

Exactly. But in March 2026, ICE released a quiet but absolutely brutal update.

SPEAKER_03

Oh man.

SPEAKER_02

They reclassified over ten common clerical errors. They moved them from the technical category, meaning they were correctable, into the substantive category. And substantive means substantive means immediate, non-correctable monetary penalties. There is no 10-day cure window anymore. If the auditor finds the mistake, the fine is automatic.

SPEAKER_03

Wow. What kind of errors are we talking about here? Because if they are complex, you know, immigration code errors, maybe the risk isn't that high for the average worker.

SPEAKER_02

Aaron Powell Well, that is the terrifying part for HR. The newly reclassified substantive violations are the exact basic mistakes an untrained friend or roommate is guaranteed to make.

SPEAKER_03

Like what?

SPEAKER_02

We are talking about missing the date of hire in section two, missing the employee's date of birth in section one, failure to date section one or section two entirely.

SPEAKER_03

Just simple dates.

SPEAKER_02

Just dates. And perhaps the most common, leaving the employer or authorized representative title blank.

SPEAKER_03

Oh, I can see exactly how that happens. A roommate signs their name in section two, but they get to the box that says title and they think, well, um, I don't work for this company. I'm just a guy. So they leave it blank.

SPEAKER_02

Exactly.

SPEAKER_03

And under the old rules, HR could just fix that. But under the new rules, that single blank box is an instant substantive violation.

SPEAKER_02

It is. And the financial impact is just staggering.

SPEAKER_03

Yeah.

SPEAKER_02

As of the latest Federal Register adjustments, fines for these paperwork violations range from $288 to $2,861 per individual form.

SPEAKER_03

Wow.

SPEAKER_02

Just for paperwork errors.

SPEAKER_03

Aaron Powell, let me just do the math on that for a second. If an enterprise company hires 500 remote workers in a year, which is common. Right. And they use the the friends and family method, and just half of those forms have a blank title or a missing date, that's 250 forms. Yep. At the maximum penalty, that's over $700,000 in fines purely for clerical errors.

SPEAKER_02

Aaron Powell And that is just the paperwork penalty. If the auditor finds evidence that the company knowingly hired unauthorized workers, the fines escalate all the way up to $28,619 per worker.

SPEAKER_03

That's bankruptcy for some companies.

SPEAKER_02

It really is. But sticking strictly to the paperwork, the removal of that 10-day cure window makes every single blank box a dicking time bomb.

SPEAKER_03

And it's not like the risk just goes away after the employee's first week, right? This introduces a legal concept that our listeners need to deeply understand when they pitch to corporations, the continuing violation.

SPEAKER_02

Oh, this is a critical point to raise in client meetings.

SPEAKER_03

Break it down for us.

SPEAKER_02

An I-9 error is not a one-time event that happened in the past. Legally, a deficient form I-9 is a live, ongoing violation for as long as that employee works for the company.

SPEAKER_03

So there's no statute of limitations.

SPEAKER_02

The statute of limitations does not protect you while the employee is active.

SPEAKER_03

Doesn't the liability even outlive their employment?

SPEAKER_02

It does. Because of the strict federal retention period, employers must keep the I-9 for three years after the date of hire, or one year after termination, whichever is later.

SPEAKER_03

So even after they leave.

SPEAKER_02

That blank title field or missing date is a findable offense sitting in a digital repository for years. Wow. This is the exact leverage you use in your pitch. The risk is simply too catastrophic for a corporation to trust an untrained civilian.

SPEAKER_03

Okay, so physical I-9s carry massive risks if executed poorly. But a logical strategist listening to this might ask: hey, if the fines are this steep and the friends and family method is a ticking time bomb, why aren't these massive tech companies just hopping on a Zoom call to look at the passports?

SPEAKER_02

Right. It seems like the obvious solution.

SPEAKER_03

Yeah. I mean they have the technology. Why not just verify documents over webcam and skip the in-person representative altogether?

SPEAKER_02

It is a great question because the technologies certainly exist, but the federal government built a massive complex firewall around remote video verification.

SPEAKER_03

Of course they did.

SPEAKER_02

On August 1st, 2023, the Department of Homeland Security made rules for remote video verification permanent. We call it the DHS alternative procedure.

SPEAKER_03

Okay.

SPEAKER_02

But they put a heavy lock on the door. The absolute prerequisite to using video verification is that the employer must be actively enrolled in e-Verify, and they must be in good standing at all applicable hiring sites.

SPEAKER_03

Okay, let's break down e-Verify for a second so everyone is on the same page.

SPEAKER_00

Exactly.

SPEAKER_03

It essentially checks if the person actually exists and is authorized to work. So if a company is not enrolled in that federal database, they cannot use video verification at all. Period.

SPEAKER_02

Correct. And even if a company is enrolled in eVerify, the rules for conducting a video verification are incredibly strict. Oh so well, it cannot just be a manager saying, hey, email me a photo of your driver's license. The interaction must be a live, real-time video call. No pre-recorded videos are allowed.

SPEAKER_03

The logistics of that live call seem pretty intense based on the DHS guidelines. How does that actual video process work?

SPEAKER_02

First, the employee has to transmit clear front and back copies of their documents to the employer before the meeting. Okay. Then they have to get on the live video call and physically hold up those exact original documents to the camera.

SPEAKER_03

So they have to show it on screen.

SPEAKER_02

Right. So the employer can verify that they match the copies sent earlier and that they reasonably appear to belong to the person on screen.

SPEAKER_03

That sounds like an administrative headache to manage like lighting, camera resolution, and document glare. And it doesn't end when the call hangs up, does it?

SPEAKER_02

No, it doesn't. Because the employer is then legally mandated to retain those clear, legible front and back copies of the documents for the entire duration of the retention period.

SPEAKER_03

Which is years.

SPEAKER_02

Exactly. And finally, the employer must check a specific box on the Form I9 indicating that the alternative procedure was used.

SPEAKER_03

Here is the danger zone, connecting back to those ICE fines we just talked about. If a company uses remote video verification to examine documents, but they are not actively enrolled in e-verify, how does ICE treat that?

SPEAKER_02

ICE now classifies that as a substantive, uncorrectable violation.

SPEAKER_03

Instant fines.

SPEAKER_02

Instant fines. You cannot retroactively fix it. If you examine documents via Zoom and you weren't on e-Verify, that I9 is permanently invalid in the eyes of an auditor.

SPEAKER_03

Aaron Powell So let's explore the market viability here. If a massive Fortune 500 company qualifies for e-Verify and they have the HR Tech stack to manage the live video and secure document storage, does the market for in-person authorized representatives just disappear for those specific companies?

SPEAKER_02

Not at all. In fact, the market for in-person physical verification remains incredibly robust even among Fortune 500s.

SPEAKER_03

Well, why?

SPEAKER_02

The reason is that many enterprise companies specifically opt out of e-Verify.

SPEAKER_03

Why would they opt out? If it allows them to use video, wouldn't they want to enroll?

SPEAKER_02

Because e-Verify carries a massive administrative burden on the back end. When you submit an employee's data to e-Verify, the system doesn't always come back with a green light. Right. Very often it returns a tentative non-confirmation or a TNC.

SPEAKER_03

A TNC, okay.

SPEAKER_02

TNC means the government databases found a discrepancy. Maybe the employee got married and changed their name, but the Social Security Administration hasn't updated it yet.

SPEAKER_03

Happens all the time.

SPEAKER_02

Right. But when a TNC happens, HR has to stop what they are doing, officially notify the employee, and the employee only has eight days to contact the government to resolve it.

SPEAKER_03

Eight days is not a lot of time for a government fix.

SPEAKER_02

It isn't. And if the HR team fails to manage that strict timeline, the company faces severe penalties. It stalls the entire onboarding pipeline.

SPEAKER_03

I see. So for a company hiring thousands of people, the sheer volume of TNCs they would have to manage makes e-Verify more expensive in human capital than it's worth.

SPEAKER_02

Exactly.

SPEAKER_03

Are there legal complexities with e-Verify across different states too?

SPEAKER_02

Immense complexities. While e-Verify is a federal program, its usage is dictated heavily by state law. States like Florida, Tennessee, and North Carolina have differing, strict e-Verify mandates for certain businesses.

SPEAKER_03

Oh wow.

SPEAKER_02

Yeah. A national company might not want to entangle their entire nationwide operation in a web of state-by-state database compliance just to satisfy the video requirements for their remote hires. They often prefer a uniform physical I-9 process across all 50 states.

SPEAKER_03

Plus, even over a high-definition webcam, some documents are just too complex to verify digitally. I mean, think about foreign nationals with complex visa documents.

SPEAKER_02

Right, it's impossible.

SPEAKER_03

A standard 720p laptop webcam isn't going to cut it when an HR manager is trying to locate microprinting or like specific holographic security features on a highly sensitive immigration document. You need a human being in the room to physically inspect it.

SPEAKER_02

Precisely.

SPEAKER_03

This is a perfect time to remind you to check out the incredible video podcast No Notary with Eddie Montes Travis.

SPEAKER_02

A must-watch.

SPEAKER_03

As well as Maryland's 90 seconds of notary. These are phenomenal resources to keep your skills sharp and your business strategies ahead of the curve as you navigate these compliance waters.

SPEAKER_02

Definitely check those out. Now, corporate America knows that mobile professionals, particularly notaries, are the perfect logistical solution for physical document inspection.

SPEAKER_03

You are mobile, you are thoroughly vetted, and you are accustomed to handling highly sensitive identity documents on a daily basis.

SPEAKER_02

Exactly. But ironically, notaries often completely bungle the execution of the I-9 because they treat it like a traditional notarization.

SPEAKER_03

Yes. This brings us to the golden rule of I-9s. If you take nothing else away from this discussion, this must be burned into your operational manual.

SPEAKER_02

Write this down.

SPEAKER_03

Completing a Form I-9 is not a notarial act.

SPEAKER_02

Let me repeat the mechanism behind that. It is not a notarial act.

SPEAKER_03

Right.

SPEAKER_02

When you are hired by a corporation to verify an I-9, you are acting exclusively as their authorized representative. Right. You are an agent of the company acting in a non-official capacity regarding your notary commission. Therefore, you must never apply your official notary seal or stamp to the form I-9.

SPEAKER_03

Never.

SPEAKER_02

In the title field of section two, you must write authorized representative. You never write notary public.

SPEAKER_03

If you stamp that form, you are instantly demonstrating to the HR director that you do not understand federal compliance. You will lose that enterprise contract immediately because a stamp has absolutely no legal standing on an I-9, and it actually confuses the document's legal status during an audit.

SPEAKER_02

I want to ground this in reality. If you are an elite compliance partner in the field, what does a disaster scenario actually look like when someone hands you their documents?

SPEAKER_03

Good question.

SPEAKER_02

Let's walk through five highly specific document scenarios that you will encounter. These scenarios separate the amateurs from the elite compliance partners.

SPEAKER_03

I love this. Let's start with a scenario in Ohio. Let's say a guy named David shows up for his I-9 verification appointment, but he was just in a car accident and he has a broken arm in the heavy cast. He literally cannot hold a pen to sign Section One of his form. What is the process here?

SPEAKER_02

This tests your knowledge of the form's deep structure. If David cannot fill out or sign Section One, he obviously needs a preparer or translator to help him. But you, as the authorized representative, cannot just fill it out for him, have him make a verbal oath, and leave it at that.

SPEAKER_03

Which people do all the time.

SPEAKER_02

They do. But anyone who helps an employee complete section one must fill out supplement A.

SPEAKER_03

Supplement A.

SPEAKER_02

Which is the preparer and or translator certification. Under the new March 2026 rules, incomplete preparer information in supplement A is a substantive violation.

SPEAKER_03

Here's that word again. Substantive.

SPEAKER_02

Exactly. You have to ensure that supplement is perfectly executed, signed, and dated by whoever helps him before you even look at his physical documents for section two.

SPEAKER_03

That is a critical procedural trap. Okay, let's move to a second scenario in Florida. You are verifying Jessica. She is an elderly employee who is coming out of retirement for a specialized consulting role.

SPEAKER_02

Happens a lot.

SPEAKER_03

She brings you a voter registration card and a social security card. But the social security card is heavily laminated, and her voter card doesn't even have a photo on it. Can you accept those?

SPEAKER_02

Let's break down the categories. The voter registration card is a list B document which establishes identity.

SPEAKER_03

Right.

SPEAKER_02

Even without a photo, a voter registration card is acceptable under federal guidelines for list B, provided it contains identifying information like name, date of birth, gender, height, eye color, and address.

SPEAKER_03

So the voter card is valid.

SPEAKER_02

Yes. Her social security card is a list C document which establishes employment authorization. However, the lamination is the trap here. Ah. If the Social Security card states on the back, not valid if laminated, the authorized representative must reject it. You have to know the physical constraints of the documents presented. You cannot accept a document that has voided itself.

SPEAKER_03

So what happens when you tell Jessica you can't accept the laminated social security car and she says, Oh, that's annoying. Let me just go to my safe and get my U.S. passport instead.

SPEAKER_02

That brings up the crucial anti-discrimination rule.

SPEAKER_03

Very important.

SPEAKER_02

The authorized representative must never steer documents. You cannot demand a U.S. passport. You cannot say a passport would be easier for me to record.

SPEAKER_03

Even if it would be.

SPEAKER_02

Even if it would be. The employee has the absolute legal right to choose which documents to present from the lists of acceptable documents.

SPEAKER_03

Okay.

SPEAKER_02

If she wants to present a list A document like a passport, great. If she wants to present a different list C document instead of the laminated card like a birth certificate, great. You simply inspect what she freely chooses to present.

SPEAKER_03

Let's look at a third scenario which is notoriously difficult. Marcus in New Jersey. Marcus is a foreign national working in the U.S. on a specific visa. He presents a foreign passport and a form I-94.

SPEAKER_02

Oh, this is where untrained reps completely fail. An untrained friend might look at a foreign passport and say, Um, I need a US document, I can't accept this.

SPEAKER_03

Which is a huge mistake.

SPEAKER_02

That is a fast track to a discrimination lawsuit. A foreign passport combined with a form I-94 bearing the same name and containing an endorsement of the individual's non-immigrant status, is a valid list A combination.

SPEAKER_03

Meaning it proves both identity and employment authorization.

SPEAKER_02

Exactly. A savvy authorized representative knows exactly how to record the foreign passport number, the issuing authority, which is the country of issuance, and the 11-digit I-94 admission number in the specific designated fields of section two. It requires intense attention to detail.

SPEAKER_03

Fourth scenario, Elena in Texas. Elena is highly protective of her personal privacy, especially regarding identity theft. She brings her Texas driver's license and her U.S. passport to the meeting.

SPEAKER_00

Okay.

SPEAKER_03

She hands you the passport and says, I'm using this, so I don't have to show you my social security number or write it on the form.

SPEAKER_02

Elena is entirely within her rights regarding the documents. A U.S. passport is a list A document. It satisfies both identity and work authorization simultaneously.

SPEAKER_03

So she doesn't need to show the license or the social security card.

SPEAKER_02

She does not need to show her driver's license or a social security card. As for writing her social security number in section one, providing an SSN is technically voluntary for the employee under standard federal rules.

SPEAKER_03

But there is a massive exception to that rule, isn't there?

SPEAKER_02

Yes. And this is where the elite strategist proves their worth. If the employer uses e-Verify, the Social Security number is mandatory in Section One.

SPEAKER_01

Really?

SPEAKER_02

Yes. The e-Verify system cannot process the query without it. You have to know the employer's specific protocol before you meet with the employee to advise Elena correctly on whether she must write her SSN in section one.

SPEAKER_03

Wow, that's nuanced.

SPEAKER_02

But regarding her physical documents, the passport is fully sufficient.

SPEAKER_03

Okay, let's look at one final scenario, Kevin, in Washington State. Kevin presents a valid state driver's license, hands it to you, and says he is ready to wrap up.

SPEAKER_02

A state driver's license is only a list B document. It only proves identity. It says nothing about his legal authorization to work in the United States. Right. A rookie mistake is recording the driver's license, assuming that's enough, and signing the form. If you do that, you just committed a substantive violation.

SPEAKER_03

Boom, instant fine.

SPEAKER_02

You must ensure Kevin also provides a list C document, like an unrestricted social security card or a birth certificate issued by a state or local authority. You must record both documents accurately in their respective columns in section two.

SPEAKER_03

These scenarios highlight exactly why this is a premium high-value service. It requires specialized knowledge. And speaking of specialized knowledge, if we are talking about state-specific nuances, we absolutely must address the ultimate state-specific landmine. Oh, yes. The California rule.

SPEAKER_02

If you operate in California or if you are pitching to an enterprise that hires remote workers in California, you must intimately understand California Business and Professions Code, sections 2244D and 22441.

SPEAKER_03

It's a big one.

SPEAKER_02

California treats the Form I-9 as an immigration document. Therefore, a California notary public cannot complete a Form I-9 for compensation unless they're also a qualified bonded immigration consultant.

SPEAKER_03

That is a massive jurisdictional hurdle. I mean, if an HR director in New York is totally unaware of this law and they hire a standard non-bonded California notary to verify an employee in San Francisco, what happens?

SPEAKER_02

That notary is operating completely outside the law. This can completely void the verification, leaving the employer liable for having an invalid I-9 on file.

SPEAKER_03

Which ironically is a massive selling point for our listeners. If you are a bonded immigration consultant in California, you are not just selling a signature, you are selling regulatory safety. Exactly. You can look that New York HR director in the eye and say, Hey, I am the bonded representative that California law requires. I protect you from voided verifications and ICE fines.

SPEAKER_02

Yeah, it's the perfect pitch. And now that you possess this high-level compliance knowledge, it is time to pivot to the application. It is time for Moneymaking Monday.

SPEAKER_03

Let's get into it.

SPEAKER_02

How do you actually monetize this knowledge at an enterprise scale? We are shifting the focus away from scraping for one-off $50 gigs on gig platforms and moving towards securing lucrative long-term B2B corporate contracts.

SPEAKER_03

Your target market here is not the individual employee who needs a form filled out. Your targets are enterprise, HR departments, national remote recruitment firms, and professional employer organizations, or PEOs.

SPEAKER_02

Yes, PEOs are huge.

SPEAKER_03

For those unfamiliar, a PEO is an outsourcing firm that provides services for small and medium businesses. They manage payroll, benefits, and HR tasks. PEOs process hundreds, sometimes thousands, of remote hires during seasonal surges. They need a scalable, reliable partner.

SPEAKER_02

To pitch these entities, you really have to understand the competitive landscape and pricing models. If you look at national competitors, you see a wide range of pricing that clearly establishes the premium market value of this service.

SPEAKER_03

What are the numbers looking like?

SPEAKER_02

Well, take a company like the Best Notary, a nationwide service. They charge between $229 and $279 per appointment for one-off verifications. Wow. They offer starter packages at $995 for just five appointments.

SPEAKER_03

Then you have regional specialists like Fingerscan Digital in California. They charge a $90 flat fee if the employee comes into their physical office, plus substantial variable travel fees for mobile execution in the field.

SPEAKER_02

Even at the enterprise software level, the pricing holds up. Equifax offers an outsourced I-9 service. They charge around $84.95 to $100 per form completion.

SPEAKER_03

Just for the form.

SPEAKER_02

And that is on top of their monthly platform access and e-verify subscription fees that the employer is already paying.

SPEAKER_03

So the market clearly supports premium pricing because of the sheer liability involved. When you pitch to a VP of human resources, you don't pitch single appointments. You structure long-term master service agreements with contractual bulk rates. You use tiered pricing to secure their high volume.

SPEAKER_02

Let's break down what a tiered structure looks like. Tier one pricing might be for a client who commits to one to fifty cases a quarter. Your rate for that tier is $150 per file.

SPEAKER_03

Okay, $150.

SPEAKER_02

It provides them a dedicated professional service and it provides you a very high profit margin.

SPEAKER_03

And as their volume grows, the price scales down to incentivize exclusivity rate. Right. Tier 2, for $51 to $150 cases, might drop to $110 per file. But the real goal is securing a tier 4 high volume contract.

SPEAKER_02

The holy grail.

SPEAKER_03

Say you land a PEO doing $500 plus hires during a Q3 seasonal ramp up. You price that volume at $75 per file. Do the math on that. At 500 cases, that is a $37,500 contract for a process that, when executed efficiently by your trained team, takes about 15 minutes per physical appointment.

SPEAKER_02

But to win those tier four contracts, corporate clients demand absolute operational guarantees. You cannot just promise you'll do a good job. You have to bind yourself to service level agreements or SLAs.

SPEAKER_03

LAs, yeah.

SPEAKER_02

These are the hard metrics by which your contract is judged and renewed.

SPEAKER_03

An enterprise SLA looks like this. First, a four-hour contact initiation. The moment HR securely transmits the new hire's info to you, your team contacts that hire within four business hours to schedule the physical meeting.

SPEAKER_02

That speed is crucial.

SPEAKER_03

Second, a 48-hour completion guarantee. You guarantee that section two will be completed, signed, and securely transmitted back to HR within 48 hours. This allows the employer to easily beat the federal three-day deadline.

SPEAKER_02

And the most important SLA of all, a 99.5% compliance accuracy rate. It is. You are contractually guaranteeing that your forms will not trigger substantive violations during an ICE audit.

SPEAKER_03

Think about this strategically. You are not selling a signature on a piece of paper. You are selling a $2,861 insurance policy against ICE fines.

SPEAKER_02

Exactly.

SPEAKER_03

How does shifting that mindset change the way you pitched? You don't walk into a boardroom and say, hey, I can look at IDs for you. You say, my firm mitigates your federal exposure. We ensure every section two is executed flawlessly, entirely insulating your company from the March 2026 ICE substantive violation penalties.

SPEAKER_02

That is a pitch a VP of HR signs off on immediately.

SPEAKER_03

It really is. And to maintain those lucrative enterprise contracts year over year, you must execute flawlessly and help employers navigate complex, unexpected operational hurdles.

SPEAKER_02

You have to be a true compliance partner, not just a vendor. One massive hidden opportunity here is mergers and acquisitions.

SPEAKER_03

MA activity is an absolute gold mine for an elite authorized representative firm. When company A buys company B, what happens to all the HR paperwork?

SPEAKER_02

It doesn't just go away. The acquiring company inherits all of the acquired company's past I-9 liabilities. The legal term for this is successor liability.

SPEAKER_03

Successor liability. So during the due diligence phase of the buyout, the acquiring company's legal team will audit the target company's I-9s. Always. If they discover terrible records, missing dates, blank titles, rampant friends and family errors, they cannot just accept those forms. If they do, they assume the massive financial liability for all those potential fines.

SPEAKER_02

The legal remedy is brutal. The acquiring company must execute entirely new I-9s for all acquired employees. And here is the kicker: they must do it within three business days of the closing date of the merger.

SPEAKER_03

Three days. Imagine a tech company acquiring a remote workforce of 300 people scattered across the country. They have 72 hours to physically verify 300 physical documents.

SPEAKER_02

It's a logistical nightmare for them.

SPEAKER_03

But it is a massive high-margin bulk rate opportunity for a coordinated authorized representative firm to deploy agents nationwide.

SPEAKER_02

Another ongoing operational hurdle you manage for your clients is reverification, which utilizes supplement B of the I-9 form.

SPEAKER_03

Ugh, supplement B.

SPEAKER_02

Employees with temporary work authorization, like certain employment authorization documents or specialized visas, have expiration dates. The employer must physically reverify their continued authorization to work before that document expires.

SPEAKER_00

Right.

SPEAKER_02

You become the retained partner to handle all physical reverifications nationwide on a rolling basis.

SPEAKER_03

To ensure your firm hits that 99.5% SLA accuracy rate across all these scenarios, you must implement a rigorous internal quality control checklist. Every form your agents touch must pass QA before it is ever sent back to the corporate client.

SPEAKER_02

The QA checklist is your final defense against those new substantive errors. First, ensure no whiteout is ever used. No. If an agent makes a mistake writing a document number, they must draw a single line through the incorrect data, write the correct information next to it, and initial and date the correction.

SPEAKER_03

Second, verify the signature sequence. The exact same person who physically viewed the original documents must be the person who signed section two.

SPEAKER_02

Very important.

SPEAKER_03

You cannot have one agent inspect the passport in the field and another agent sign the form later back in the office.

SPEAKER_02

Third, meticulously check the date formatting. Ensure all dates use a four-digit year in the YYY format.

SPEAKER_03

It seems minor, but strict appearance prevents digital rejection if the employer uses an API integration to feed the data into their HR software.

SPEAKER_02

Here is a scenario that tests your QA protocol. What do you do if the employer sends you a partially filled Form I9 and Section 2 has a blank hire date? And the remote employee sitting in front of you says, Um, I don't know my exact official start date yet. HR hasn't told me, just leave it blank.

SPEAKER_03

That's a trap.

SPEAKER_02

You halt the process immediately. The authorized representative must decline to sign the form in that moment. You escalate it back to your corporate HR contact and require them to provide the exact start date. Because leaving it blank is guessing the date or leaving it blank is now an uncorrectable substantive violation under the March 2026 rules. You protect the client by refusing to execute a non-compliant document, even if it delays the process by an hour.

SPEAKER_03

It is about strict, uncompromising adherence to the process. As we wrap up the session, I want to leave you with a broader concept to ponder. We are rapidly moving into an era of massive digital integration and compliance.

SPEAKER_02

We really are.

SPEAKER_03

With the rise of digital I9 repositories and government API integrations, an ICE auditor no longer has to physically walk into an HR office and sift through dusty paper boxes.

SPEAKER_02

The audit process is becoming entirely digital and automated. An auditor can simply run a digital script against an employer's entire cloud database. Wow. That script can find every missing date, every blank title, and every formatting error across 10,000 forms in mere milliseconds.

SPEAKER_03

In an era where digital tools make identifying errors absolutely instantaneous, the value of a perfectly trained human authorized representative in the field has never been higher.

SPEAKER_02

Never.

SPEAKER_03

The technology can flag the errors with terrifying speed, but only a human can prevent them at the moment of physical verification. The ultimate question for you, the savvy strategist, is this Will you be the one providing that flawless execution to corporate America?

SPEAKER_02

We want to hear your thoughts, your strategies, and your questions as you build out this B2B vertical. Please email your questions to Derek at Dereksbruel.com. We will try to answer as soon as possible at the end of our shows.

SPEAKER_03

Exec producer Derek Sprill, lead writer Marilyn Lee Trotter, graphics Eddie Montez Travis, music Thomas Bynum, produced by Magnificent Works Business Solutions. Don't just be listeners of the knowledge, be doers of the knowledge. This is notary knowledge. Until next time.

SPEAKER_01

Are you an aspiring notary looking to join millions of other notaries? Start your journey with the Notary Public Foundation by Derek Sproeil. This essential guide provides the step-by-step process to becoming commissioned in your state. Don't stumble into the role. Walk into it with confidence. Grab your copy of the Notary Public Foundation by Derek Sproeil on Amazon today.