We just got a copy of the PowerPoint slides used at the Department of Labor Stakeholders Meeting held on Monday in Washington, D.C. You can download a copy of the DOL persuader presentation here. The most important slides for employers are pages 9 and 10. The DOL’s position appears to be that the 203(e) exemption for employer reporting conflicts with Sections 203(a)(2) and 203(a)(3) that require reporting of activities of employees under certain circumstances. We are working on an analysis of this issue for clients. We will keep you posted on the latest developments here.
