A huge part of Donald Trump's surge to the top of the polls in the GOP nomination race is the perception that he's going to be tough on immigration. Exit polls from a number of states have shown that he's the favored candidate among voters who believe immigration is one of the most serious issues we face as a nation. But voters who think Trump will take a tough stand on immigration — legal, illegal, visas, and guestworkers — should consider his company's hiring track record.

Last year, Reuters and some local media outlets in South Florida reported that Trump's company has used more than 1,100 guest workers via the H-2B visa program, which is for seasonal, unskilled, non-agricultural jobs. And on Thursday, the New York Times published an investigative piece detailing how extensively Trump's signature Mar-a-Lago Club in South Florida has utilized guest workers.

I wrote an in-depth report on H-2Bs in 2010, and I interviewed many H-2B visa applicants as a Foreign Service officer. The H-2B program is more or less despised by both sides of the immigration debate. The human rights community considers the program legalized slavery, and those who advocate stricter immigration enforcement believe that H-2B workers contribute to unemployment and wage stagnation for U.S. workers. But the business community loves this program because it brings them cheap, reliable labor — people who can't quit or demand better working conditions.

Trump's company is certainly not alone in leaning on this program for guestworkers. And I'm sure his supporters will wonder why the media hasn't shown much interest in covering other companies that use and abuse the guest worker program. But when you put yourself out there as a guy who is going to champion American workers, as Trump has, you had better be prepared to defend your company's hiring practices. For his part, Trump has claimed, essentially, that it's hard to find good help these days, and that since this program is legal, there is nothing wrong. I suspect that very few voters will buy this argument.

I combed through the government databases detailing H-2B petitions and here are some observations regarding the Trump Organization's use of H-2B guest workers:

In petitioning for workers, employers are supposed to prove that their hiring need is "seasonal" and "temporary", yet Trump's Mar-a-Lago Club has sought to import guest workers year after year, including right now. (Their most recent petition was filed in July 2015 and the workers are on contract at the resort until May 31, 2016.)





Trump maintained at the debate on Thursday night that the jobs he had filled with guest workers were hard to fill because they were only for 90 or 120 days. But in fact, the duration of the petitions was never just three months. The work period for Mar-a-Lago's guest workers, according to the petitions, is nearly always October 1 to May 31, which is 8 months. On other occasions, his company petitioned for even longer periods. For example, in 2009, the Trump National Golf Club petitioned for guest workers for the period January 26 through November 20.





I note that even during the height of the recession, this and other Trump properties were petitioning for workers.





In 2009, again, during the height of the recession, the Trump Organization used an H-2B broker called Más Labor to import workers. Más Labor extols the benefits of Mexican workers on their website, which allows employers to add guest workers to their online shopping carts. "You'll never wonder if your workers are going to show up on Monday morning and make it through a full work week," it reads. "MAS H2 workers are dedicated to their families, their work and their employers. They'll be there, ready to work hard for you. ... The only thing an H2 worker can do legally in the U.S. is work for their specified employer. ... For Mexican workers, seven to nine dollars an hour is about ten times what could be earned in most jobs at home."





Más Labor is run by Elizabeth Whitley, a former congressional aide who is on the board of Save our Small Businesses, a leading advocacy group that lobbies Congress for guest workers. As I reported in 2010, it is essentially a consortium of medium and large businesses that rely heavily on guest workers masquerading as a group of small businesspeople. (Trump's companies also relied heavily on another individual based in Ithaca, N.Y., Peter Petrina.)





Based on the databases, it looks like the Trump Organization often pays workers exactly whatever the Department of Labor sets as the prevailing wage for that type of job and not a penny more. So, for example, in 2010 housekeepers at Mar-a-Lago got $7.44, but right now they get $10.07 as the prevailing wage has gone up.





Many employers use shell companies and what we used to call "body shops", which are brokers who petition for workers and then parcel them off to companies that need them. This means that the Trump Organization's use of seasonal guest workers could be even more significant than what we see in the databases.



