To get approval for H-2B visas, employers must prove they need extra workers and that they made an effort to recruit domestic workers, contacted everyone who responded to ads and hired all qualified applicants. After receiving approval, employers must petition U.S. Citizenship and Immigration Services to bring foreign, temporary workers into the country.

Trump has made the case that he couldn't find American workers. "It's almost impossible to get help," the Republican presidential candidate told CNN last month. "And part of the reason you can't get American people is they want full time jobs."

That is news to Tom Veenstra. He is senior director of support services at the Palm Beach County CareerSource office. It's a free service that links qualified job candidates with employers. And during the past two years, the agency has placed more than 50,000 people in jobs in Palm Beach County. Veenstra says he has no doubt he could fill Mar-a-Lago with U.S. workers.

"We have hundreds of qualified candidates for jobs like these," Veenstra told CNN. "That's what we do here. We help place local residents into jobs like those."

Did Trump use the free service? Only once, Veenstra says. After criticism about its hiring practices, Mar-a-Lago asked the Palm Beach County CareerSource office to send over qualified candidates for a single position. Veenstra says he sent four applicants, one was hired.

Veenstra says there were no problems with the hire as far as he knows, but they never had another request from Mar-a-Lago.

Mar-a-Lago positions paid roughly $10 an hour for maids and housekeepers going up to $13 an hour for cooks, and about $11 for waiters and waitresses.

The Department of Labor requires proof that an employer seeking to import workers tried but failed to attract qualified U.S. workers.

Records show Mar-a-Lago appears to have done the bare minimum required by law. According to a CNN analysis of hundreds of pages of Labor Department documents, Mar-a-Lago did not place advertisements in the area's largest newspaper. Instead, ads were placed in a local paper with a small circulation and the ads were routinely posted for just two days, the minimum required by law.