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Neil Schulman

One of the key components to the OFCCP requirement is that the person applying for the job has to be qualified. You don't have to consider someone an applicant just because they apply. Companies looking to comply need to establish job-related minimum qualifications criteria. Many companies establish qualification criteria that may not be job related (e.g., requiring a high school degree for an unskilled laborer).

The record keeping requirements are ambiguous and difficult to follow given the ability of recruiters to search multiple sources of applicants over the internet.

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