The actual function-manager conditions require assessment; there is no universal direct-report quota. The applicant must principally manage the essential function rather than perform its work.
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Do not treat the absence of direct reports as either automatic approval or automatic refusal.
The regulation defines managerial capacity in two ways: managing the organization or a department and supervising professional, supervisory or managerial staff with hiring authority, or managing an essential function at a senior level with discretion over its daily operations. A manager supervises and controls an organization, department, function, or component at a qualifying level; an executive directs major goals and policies with broad discretion. Qualifying employment abroad is generally one continuous year within the relevant preceding three-year period, and the assessment looks at the work performed rather than only the final title. Where several family members or holding entities are involved, have counsel assess actual control from the corporate records rather than from a simplified description. Personnel management is measured by the character of the employees supervised, so a general manager with a large but non-professional crew can fall outside it while a director with three analysts falls inside.