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Herman Legal Group

Full company profile

uuid000t785

Namestring
Herman Legal Group
Legal namestring
Herman Legal Group, LLC
Company typeenum
Private
Founded yearint
1995
Descriptiontext

Herman Legal Group, LLC is a Cleveland, Ohio-based law firm founded in 1995 by Richard Herman, specializing in U.S. immigration law and related legal services. The firm serves individuals, families, SMBs, and nonprofit/religious organizations across all 50 states and internationally, delivered through two Ohio offices (Cleveland headquarters, Columbus) and a virtual consultation channel. The core practice spans family-based immigration (marriage green cards, fiancé visas, family petitions), employment-based immigration (H-1B, labor certification, PERM), removal/deportation defense, naturalization, investor visas (E-2, EB-5), student and tourist visas, immigration waivers, and humanitarian relief (asylum, U-visa, T-visa, DACA). Adjacent service lines include criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark, and employment disputes, broadening wallet share with existing immigration clients.

The business model is professional services legal fees on a quote-based, case-by-case engagement basis with multi-year contract duration tied to immigration case lifecycles. The firm employs approximately 11-50 people including at least 8 attorneys (Richard Herman, Vania Stefanova, Luis Villarroel, Tameem Ansari, Ruijie Zhang, Frank Krajenke, Charmaine Rozario, Erin James) plus a paralegal team led by Chief Paralegal Connie Cook. Technology infrastructure is limited to case management systems and standard virtual consultation tools; there is no proprietary technology platform, no disclosed AI/ML capabilities, and no product/engineering function. Demand generation is built on a content marketing engine (immigration blog, newsletter, social), earned media (NYT, Forbes, NPR, Bloomberg Businessweek, USA Today), the founder's authored book 'Immigrant, Inc.', and multilingual community reach across Spanish, Arabic, Chinese, French, Hindi, Russian, Farsi, Dari, and English.

The firm is privately held with no external investors, no parent company, and no subsidiaries. Revenue is not publicly disclosed. Competitive positioning is anchored in founder reputation (AV Preeminent Martindale Hubbell rating, AVVO Top 10, Super Lawyers, Best Lawyers, Lead Counsel), a 4.8 Google rating with hundreds of five-star reviews, and a longstanding public policy voice through Richard Herman's role as a speaker for the Partnership for a New American Economy. The principal concentration risk is key-person dependence on Richard Herman for both the brand and the policy/public profile of the firm.

Short descriptiontext

Herman Legal Group is a Cleveland, Ohio-based immigration and general legal services law firm founded in 1995 by Richard Herman. It serves individuals, families, SMBs, and religious/nonprofit organizations across all 50 states and internationally through two Ohio offices and virtual consultations.

Operating statusenum
Operating
Ownership categoryenum
Headcount rangeband
11–50
akta.pro rankint
HeadquartersCleveland, United States
HQ citystring
Cleveland
HQ countrystring
United States
HQ regionstring
North America
Markets served

Serves global market

Offices2 records

Each record includes

City, Country, Type, Description, Source

Keyword5 values
immigration law services, deportation defense, family-based immigration, employment-based immigration, naturalization services
Industry4 codes
1Immigration Law
CodeBPAHAAALPrimaryYes
2Immigration, Visa & Work Authorization Support
CodeHSAKAJAFPrimaryNo
3Immigration Legal Services & Representation (Law Firms)
CodeTHACAKAFPrimaryNo
4Employment & Labor Law
CodeBPAHAAADPrimaryNo
NAICS code2 codes
  • Offices of Lawyers541110
  • Legal Services5411
SIC code1 code
  • Services-Legal Services8111
Product category
Immigration Legal Services
GTM motion1 record

Each record includes

Type, Description, Source

Revenue model1 record
1Legal Services
TypeProfessional Services
Description

The firm generates revenue through professional legal services fees. Services include immigration law representation (family-based, employment-based, deportation defense, naturalization, investor visas, student visas, tourist visas), criminal defense, divorce and family law, personal injury, and business/IP/trademark law. Clients pay for legal consultations, case representation, and document preparation services.

lawfirm4immigrants.com
Marketing channels6 records

Each record includes

Title, Type, Stage, Description, Source

Distribution channels2 records

Each record includes

Title, Type, Scope, Target buyer, Description, Source

Cost components5 values
Personnel, Operations, Marketing or Sales, Technology or R&D, Infrastructure
Pricing details1 tier
1Legal consultation and case representation services
ModelOtherBilling cadenceMulti-year contract
Notes

Pricing not publicly disclosed. Services are quote-based with initial consultation followed by legal agreement and secure payment options.

lawfirm4immigrants.com
GTM typeB2C
B2C
Offering typeServices
Services
Core offering1 text field

Herman Legal Group is a U.S. immigration and general legal services law firm providing representation across family-based immigration (marriage green cards, fiancé visas), employment-based immigration (H-1B, labor certification, PERM), removal/deportation defense, naturalization, investor visas (E-2, EB-5), student and tourist visas, waivers, and humanitarian relief (asylum, VAWA, U-visas, T-visas, DACA). The firm also provides ancillary legal services including criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark law, and employment disputes. Revenue is earned through professional legal service fees billed to clients.

Differentiator
Functional benefit
Problem solved
Quantifiable outcome1 of 3 values shown
  • Thousands of successful cases with immigrants achieving legal status, avoiding deportation, and securing permanent residency
+2 more records
Product overview1 text field

Herman Legal Group is a multilingual immigration and general legal services law firm offering a comprehensive portfolio of legal services. The core offering centers on immigration law, including family-based immigration (marriage green cards, fiancé visas), employment-based immigration (H-1B, work visas, labor certification), deportation defense, asylum, naturalization, investor visas (E-2, EB-5), student/tourist visas, and humanitarian relief. Beyond immigration, the firm provides criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark law, and employment disputes. The firm also publishes the book 'Immigrant, Inc.' as a thought leadership resource. The practice serves clients nationwide with offices in Cleveland and Columbus, Ohio, and offers virtual consultations globally.

Product and service16 records
1Family-Based Immigration
2Employment-Based Immigration
3Removal and Deportation Defense
4Naturalization and Citizenship
5Investor-Based Immigration
6Immigration Waivers
7International Student Visa Services
8Tourist Visa Services
9Asylum and Humanitarian Relief
10Criminal Defense Services
11Crimmigration Services
12Divorce and Family Law
13Serious Injury and Accident Legal Services
14Business, IP, and Trademark Law
15Employment Disputes
16Victims of Violence Services
Scale indicator5 records

Each record includes

Type, Value, Description, Source

Partnership1 partner
1Partnership for a New American Economy
Strategic tierCoreTypeStrategic or Co-development Partner
Description

Richard Herman serves as a speaker on behalf of this initiative founded by NYC Mayor Michael Bloomberg. The partnership is a national coalition of over 400 CEOs and mayors who advocate for smart immigration policies that strengthen America's economic competitiveness.

lawfirm4immigrants.com
Recent move5 records

Each record includes

Date, Type, Title, Description, Source

Expansion highlight4 records

Each record includes

Type, Description

Peers10 records
TypeBroad incumbent
Description

Large immigration-focused law firm with global footprint and tech-enabled case management. Directly comparable practice mix (employment-based, family-based, deportation defense, investor visas) at much larger enterprise scale.

TypeBroad incumbent
Description

Global full-service law firm with a substantial business immigration practice. Comparable at the high end for investor visas and corporate immigration; broader portfolio than Herman Legal Group.

TypeDirect peer
Description

Boutique immigration law firm known for high-profile celebrity and athlete visa work. Directly comparable as a specialist immigration-only firm serving individual and family clients across the full immigration stack.

TypeEmerging player
Description

Tech-enabled immigration services platform targeting marriage-based green cards, naturalization, and citizenship. Emerging direct competitor in the lower-complexity segments of Herman Legal Group's family-based practice.

TypeBroad incumbent
Description

Major U.S. labor and employment law firm with a sizable immigration practice serving corporate clients. Comparable in employment-based immigration capability, though it serves primarily employer-side matters at much larger scale.

TypeDirect peer
Description

New York-based immigration boutique led by a recognized thought leader, comparable in size and service breadth. Direct peer in complex employment-based immigration and deportation defense.

TypeBroad incumbent
Description

Global leader in immigration law with offices across the Americas, Europe, Asia and Africa. Comparable as a specialist immigration firm serving corporate and individual clients across all major visa categories; Herman Legal Group operates at significantly smaller scale.

TypeOthers
Description

Nonprofit provider of low-cost and pro bono immigration legal services including naturalization, asylum, and family-based filings. Not a direct competitor (free/subsidized services) but addresses overlapping client demand in humanitarian and naturalization work.

TypeDirect peer
Description

Mid-market immigration firm known for H-1B and employment-based practice with strong thought leadership and content output. Comparable business model and visa-category focus.

TypeDirect peer
Description

Mid-sized immigration-focused firm with strong EB-5 and employment-based practice. Closely comparable in service mix and target clientele to Herman Legal Group.

Market position
Strengths5 records

Each record includes

Headline, Details, Source

Weaknesses5 records

Each record includes

Headline, Details, Source

Competitive moat4 records

Each record includes

Type, Details

Key risks6 records

Each record includes

Headline, Details, Source

Key highlights7 records

Each record includes

Headline, Details, Source

Customer concentration

Classification, Details

Named customers17 records

Each record includes

Name, Industry, Type, Use case, Source, UUID

Segment8 records

Each record includes

Title, Type, Primary, Description, Pain point addressed, Use case, Source

Ideal customer profile5 records

Each record includes

Profile, Firmographic size, Sales motion, Sales cycle length, Buying structure, Purchase trigger, Buyer persona, Geography, Industry vertical, Primary use case, Description, Pain points, Evidence proof points, Target buyer

Technology focused
No
API detail
Has APIbool
No

Docs URL, Description

AI maturity
App detail

Has app

Core technology
Revenue estimate
Valuation estimate
Number of profiles
Profiles9 records

Each record includes

Name, Designation, Designation category, Overview, Profile commentary, Source

No data
No data
Funding overview

Funding stage, Last funding date, Total funding USD

Funding rounds

Each record includes

Round, Amount USD, Date, Pre money valuation, Total investors, Investors, News

Investors

Each record includes

Name, Type, Date of entry, Rounds participated, Website

Funding detail is available on the Subscription and Enterprise plan.Contact sales →

M&A

Each record includes

Name, Acquisition type, Announced date, Completed date, Status, Website, News

Investment

Each record includes

Name, Round, Announced date, Lead investor, Website, News

M&A and investment is available on the Subscription and Enterprise plan.Contact sales →

Herman Legal Group

Immigration Legal Serviceslawfirm4immigrants.com

Herman Legal Group is a Cleveland, Ohio-based immigration and general legal services law firm founded in 1995 by Richard Herman. It serves individuals, families, SMBs, and religious/nonprofit organizations across all 50 states and internationally through two Ohio offices and virtual consultations.

What Herman Legal Group does

Herman Legal Group, LLC is a Cleveland, Ohio-based law firm founded in 1995 by Richard Herman, specializing in U.S. immigration law and related legal services. The firm serves individuals, families, SMBs, and nonprofit/religious organizations across all 50 states and internationally, delivered through two Ohio offices (Cleveland headquarters, Columbus) and a virtual consultation channel. The core practice spans family-based immigration (marriage green cards, fiancé visas, family petitions), employment-based immigration (H-1B, labor certification, PERM), removal/deportation defense, naturalization, investor visas (E-2, EB-5), student and tourist visas, immigration waivers, and humanitarian relief (asylum, U-visa, T-visa, DACA). Adjacent service lines include criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark, and employment disputes, broadening wallet share with existing immigration clients.

The business model is professional services legal fees on a quote-based, case-by-case engagement basis with multi-year contract duration tied to immigration case lifecycles. The firm employs approximately 11-50 people including at least 8 attorneys (Richard Herman, Vania Stefanova, Luis Villarroel, Tameem Ansari, Ruijie Zhang, Frank Krajenke, Charmaine Rozario, Erin James) plus a paralegal team led by Chief Paralegal Connie Cook. Technology infrastructure is limited to case management systems and standard virtual consultation tools; there is no proprietary technology platform, no disclosed AI/ML capabilities, and no product/engineering function. Demand generation is built on a content marketing engine (immigration blog, newsletter, social), earned media (NYT, Forbes, NPR, Bloomberg Businessweek, USA Today), the founder's authored book 'Immigrant, Inc.', and multilingual community reach across Spanish, Arabic, Chinese, French, Hindi, Russian, Farsi, Dari, and English.

The firm is privately held with no external investors, no parent company, and no subsidiaries. Revenue is not publicly disclosed. Competitive positioning is anchored in founder reputation (AV Preeminent Martindale Hubbell rating, AVVO Top 10, Super Lawyers, Best Lawyers, Lead Counsel), a 4.8 Google rating with hundreds of five-star reviews, and a longstanding public policy voice through Richard Herman's role as a speaker for the Partnership for a New American Economy. The principal concentration risk is key-person dependence on Richard Herman for both the brand and the policy/public profile of the firm.

Herman Legal Group firmographics

Firmographics
Name
Herman Legal Group
Legal name
Herman Legal Group, LLC
Website
https://lawfirm4immigrants.com
Company type
Private
Founded year
1995
Operating status
Operating
Headcount range
11–50 employees
Short description
Herman Legal Group is a Cleveland, Ohio-based immigration and general legal services law firm founded in 1995 by Richard Herman. It serves individuals, families, SMBs, and religious/nonprofit organizations across all 50 states and internationally through two Ohio offices and virtual consultations.
Ownership category
akta.pro rank

Herman Legal Group industry classification

Industry
Product category
Immigration Legal Services
NAICS
Offices of Lawyers (541110), Legal Services (5411)
SIC
Services-Legal Services (8111)
akta.pro primary industry
Immigration Law (BPAHAAAL)
akta.pro secondary industries
Immigration, Visa & Work Authorization Support (HSAKAJAF), Immigration Legal Services & Representation (Law Firms) (THACAKAF), Employment & Labor Law (BPAHAAAD)

Keywords

  • Immigration law services
  • Deportation defense
  • Family-based immigration
  • Employment-based immigration
  • Naturalization services

Where Herman Legal Group is headquartered

Location

Headquarters

HQ city
Cleveland
HQ country
United States
HQ region
North America

Offices2 records

Markets served

Herman Legal Group business model

Business model
GTM type
B2C
Offering type
Services
Cost components
Personnel, Operations, Marketing or Sales, Technology or R&D, Infrastructure

Revenue model

  1. Legal Services: The firm generates revenue through professional legal services fees. Services include immigration law representation (family-based, employment-based, deportation defense, naturalization, investor visas, student visas, tourist visas), criminal defense, divorce and family law, personal injury, and business/IP/trademark law. Clients pay for legal consultations, case representation, and document preparation services.

Pricing tiers

ModelBillingPrice
OtherMulti-year contractLegal consultation and case representation services

Go-to-market motion1 record

Distribution channels2 records

Marketing channels6 records

Herman Legal Group product offering

Product offering

Core offering

Herman Legal Group is a U.S. immigration and general legal services law firm providing representation across family-based immigration (marriage green cards, fiancé visas), employment-based immigration (H-1B, labor certification, PERM), removal/deportation defense, naturalization, investor visas (E-2, EB-5), student and tourist visas, waivers, and humanitarian relief (asylum, VAWA, U-visas, T-visas, DACA). The firm also provides ancillary legal services including criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark law, and employment disputes. Revenue is earned through professional legal service fees billed to clients.

Product overview

Herman Legal Group is a multilingual immigration and general legal services law firm offering a comprehensive portfolio of legal services. The core offering centers on immigration law, including family-based immigration (marriage green cards, fiancé visas), employment-based immigration (H-1B, work visas, labor certification), deportation defense, asylum, naturalization, investor visas (E-2, EB-5), student/tourist visas, and humanitarian relief. Beyond immigration, the firm provides criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark law, and employment disputes. The firm also publishes the book 'Immigrant, Inc.' as a thought leadership resource. The practice serves clients nationwide with offices in Cleveland and Columbus, Ohio, and offers virtual consultations globally.

Differentiator

Problem solved

Functional benefit

Products and services

  • Family-Based Immigration
  • Employment-Based Immigration
  • Removal and Deportation Defense
  • Naturalization and Citizenship
  • Investor-Based Immigration
  • Immigration Waivers
  • International Student Visa Services
  • Tourist Visa Services
  • Asylum and Humanitarian Relief
  • Criminal Defense Services
  • Crimmigration Services
  • Divorce and Family Law
  • Serious Injury and Accident Legal Services
  • Business, IP, and Trademark Law
  • Employment Disputes
  • Victims of Violence Services

Quantifiable outcome

  • Thousands of successful cases with immigrants achieving legal status, avoiding deportation, and securing permanent residency
  • +2 more outcomes

Companies that use Herman Legal Group

Customer profile

Named customers17 records

Segments8 records

Ideal customer profiles5 records

Herman Legal Group technology and API

Technology

Technology focussed No

API detail

Has API
No
API docs
API detail

Core technology

AI maturity

App detail

Herman Legal Group partnerships and signals

Strategic signal

Partnerships

One partnership is on record.

  • Partnership for a New American EconomycoreStrategic or Co-development PartnerRichard Herman serves as a speaker on behalf of this initiative founded by NYC Mayor Michael Bloomberg. The partnership is a national coalition of over 400 CEOs and mayors who advocate for smart immigration policies that strengthen America's economic competitiveness.

Scale indicators5 records

Recent moves5 records

Expansion highlights4 records

Herman Legal Group competitors and assessment

Company assessment

Broad incumbents

  • Berry Appleman & Leiden (BAL): Large immigration-focused law firm with global footprint and tech-enabled case management. Directly comparable practice mix (employment-based, family-based, deportation defense, investor visas) at much larger enterprise scale.
  • Greenberg Traurig: Global full-service law firm with a substantial business immigration practice. Comparable at the high end for investor visas and corporate immigration; broader portfolio than Herman Legal Group.
  • Ogletree Deakins: Major U.S. labor and employment law firm with a sizable immigration practice serving corporate clients. Comparable in employment-based immigration capability, though it serves primarily employer-side matters at much larger scale.
  • Fragomen, Del Rey, Bernsen & Loewy: Global leader in immigration law with offices across the Americas, Europe, Asia and Africa. Comparable as a specialist immigration firm serving corporate and individual clients across all major visa categories; Herman Legal Group operates at significantly smaller scale.

Direct peers

  • Wolfsdorf Rosenthal LLP: Boutique immigration law firm known for high-profile celebrity and athlete visa work. Directly comparable as a specialist immigration-only firm serving individual and family clients across the full immigration stack.
  • Cyrus D. Mehta & Associates PLLC: New York-based immigration boutique led by a recognized thought leader, comparable in size and service breadth. Direct peer in complex employment-based immigration and deportation defense.
  • Siskind Susser PC (VisaGreer / visalawyer.com): Mid-market immigration firm known for H-1B and employment-based practice with strong thought leadership and content output. Comparable business model and visa-category focus.
  • Klasko Immigration Law Partners: Mid-sized immigration-focused firm with strong EB-5 and employment-based practice. Closely comparable in service mix and target clientele to Herman Legal Group.

Emerging players

  • Boundless Immigration: Tech-enabled immigration services platform targeting marriage-based green cards, naturalization, and citizenship. Emerging direct competitor in the lower-complexity segments of Herman Legal Group's family-based practice.

Others

  • Catholic Charities Migration & Refugee Services: Nonprofit provider of low-cost and pro bono immigration legal services including naturalization, asylum, and family-based filings. Not a direct competitor (free/subsidized services) but addresses overlapping client demand in humanitarian and naturalization work.

Market position

Strengths5 records

Weaknesses5 records

Competitive moat4 records

Key risks6 records

Key highlights7 records

Customer concentration

Herman Legal Group social profiles

Digital presence

Herman Legal Group financial estimates

Financial estimate

Revenue estimate

Valuation estimate

Herman Legal Group leadership team

Management profile

Number of profiles

Profiles9 records

Herman Legal Group funding detail

Funding detail

Funding overview

Funding rounds

Investors

Funding detail is available on the Subscription and Enterprise plan.Contact sales →

Herman Legal Group M&A and investment

M&A and investment

M&A

Investments

M&A and investment is available on the Subscription and Enterprise plan.Contact sales →

Frequently asked questions about Herman Legal Group

What does Herman Legal Group do?

Herman Legal Group is a U.S. immigration and general legal services law firm providing representation across family-based immigration (marriage green cards, fiancé visas), employment-based immigration (H-1B, labor certification, PERM), removal/deportation defense, naturalization, investor visas (E-2, EB-5), student and tourist visas, waivers, and humanitarian relief (asylum, VAWA, U-visas, T-visas, DACA). The firm also provides ancillary legal services including criminal defense, crimmigration, divorce/family law, personal injury, business/IP/trademark law, and employment disputes. Revenue is earned through professional legal service fees billed to clients.

Is Herman Legal Group a public or private company?

Herman Legal Group is a private company. It is classified as founder individual operated bootstrapped and is currently operating.

When was Herman Legal Group founded?

Herman Legal Group was founded in 1995. It employs 11 to 50 people.

Where is Herman Legal Group based?

Herman Legal Group is headquartered in Cleveland, United States, in the North America region.

How does Herman Legal Group make money?

One revenue line is on record: legal Services.

Who are Herman Legal Group's main competitors?

Broad incumbents on record are Berry Appleman & Leiden (BAL), Greenberg Traurig, Ogletree Deakins and Fragomen, Del Rey, Bernsen & Loewy. Direct peers are Wolfsdorf Rosenthal LLP, Cyrus D. Mehta & Associates PLLC, Siskind Susser PC (VisaGreer / visalawyer.com) and Klasko Immigration Law Partners. Boundless Immigration is listed as an emerging player. Catholic Charities Migration & Refugee Services is listed as an others.

Does Herman Legal Group have an API?

No public API is recorded for Herman Legal Group.

What industry is Herman Legal Group in?

Herman Legal Group's product category is Immigration Legal Services. Its primary akta.pro industry code is BPAHAAAL, Immigration Law, with a secondary code of HSAKAJAF, Immigration, Visa & Work Authorization Support. Its NAICS code is 541110 and its SIC code is 8111.

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Live signals
SalonThe humiliation of Tom HomanTom Homan, Trump's border czar, reversed his July 14 defense of a temporary ICE vehicle-stop suspension after two shootings, ordering stops to resume. The reversal left officials unable to communicate operational policy, undermining accountability and agency authority.IntpolicydigestAmerica is Building a National Police Force Through ICEICE suspended vehicle stops after two fatal shootings, then reversed the decision under political pressure. Congress provided $74.85 billion in supplemental funding through 2029, and ICE hired about 12,000 officers, with net gains of roughly 6,200. The expansion outpaced vetting and training, raising accountability concerns.CounterpunchWhen ICE Kills, “Trust Us” Is Not EvidenceICE officer fatally shot Lorenzo Salgado Araujo in Houston on July 7, 2025, during a targeted enforcement operation. The government claims he rammed a vehicle and tried to run over the agent, but the family says he was a construction worker with no criminal record. The author demands full release of video and evidence, noting DHS agents had no body cameras.Ohio Capital JournalOhio should treat citizenship as civic infrastructure • Ohio Capital JournalThe author argues Ohio should treat naturalization as civic infrastructure, opposing a DHS proposal to raise application fees by 75-80% to $1,330 for paper filings. The proposal would also eliminate reduced fees and waivers, making citizenship harder for working families. The author urges protecting fee relief and supporting community programs.GoverningWe Don’t Need 50 Immigration SystemsMississippi passed SB 2114, criminalizing immigration-related conduct and authorizing its Department of Public Safety to identify undocumented immigrants and seek 287(g) agreements. The law targets a state with about 27,000 undocumented residents, less than 3% foreign-born. The author warns that states are building immigration systems in a federal vacuum, risking fragmentation and inconsistent rules.IndustryweekReshoring Needs Immigrant Workers, Not Work Permit ChaosThe author argues that reshoring depends on predictable work authorization, citing a DHS rule that ends automatic extensions for many renewal applicants. U.S. manufacturing could need 3.8 million additional workers by 2033, with 1.9 million potentially unfilled. The piece calls for integrating immigration policy into industrial planning.NPRImmigration lawyers report 'chaos' over Trump’s new green card rules : Here & Now AnytimeThe Trump administration issued new rules requiring green card applications from abroad, a change from the usual practice. Immigration attorney Richard Herman reported chaos among clients and noted what remains unclear. The rules were announced last Friday.