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Can a parent company create sub-accounts for each subsidiary to assume responsibility for its own filings?

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If a parent entity wishes to centralize administration/control over PERM filings of its subsidiaries having different FEINs, can the parent company create sub-accounts for each subsidiary and then permit each subsidiary to assume responsibility for its own filings?

According to the Labor Department:

No, a parent company can not create sub-accounts for subsidiaries having FEINs different from that of the parent company in order to centralize administration and control. When an application is being completed using a sub-account, employer information from the main account, including FEIN and address, is automatically populated into the application and that information can not physically be changed or altered.
‹ How can the employer ensure that no unauthorized use of the employer's PIN and/or usernames and passwords exists?upWill the National Processing Centers issue confirmations of receipt for mail-in applications? ›

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