The guidance provides that O and P-1 petitions filed by agents are subject to several conditions. For petitions involving multiple employers filed by an agent for both the employer and beneficiary, the petition must include:
- a complete itinerary of events or services or engagements
- the itinerary must specify dates, names and addresses of actual employers, names and addresses of venues and locations
- contracts between employer and beneficiary, and
- an explanation of terms and conditions of employment
Where the employer is “in the business as an agent,” petitioner must establish that it is authorized to act as an agent for other employers for purposes of filing the petition. This can be demonstrated by a signed statement from beneficiary employers stating that the agent is authorized to act in the employer’s place for the limited purpose of filing the O or P petition. The memorandum reviews other qualifying evidence establishing authority of the agent ncluding contracts, fee arrangements, and other statements. The memorandum also provides that the validity period may only be authorized for the qualifying events set forth by the petitioner. The memorandum finally sets out definitions for sponsoring organization in the context of P petitions. Related Links Memo, Neufeld, Acting Assoc. Dir., Domestic Oper., HQ 70/6.2.18 (Nov. 20, 2009) USCIS, Press Release, USCIS Clarifies Requirements for Agents Filing as Petitioners for O and P Visa Classifications
