UPDATE 6/16/16 –
Last week the Department of Labor created a very brief “grandfather” period for persuader agreements entered into BEFORE July 1, 2016. If you wish to have one of these Agreements on file please click here to ask for a copy. For more information see below.
The Department of Labor (DOL) recently changed what it considers reportable “persuader” activity. Any agreements entered into AFTER July 1, 2016 with attorneys or consultants to provide a number of common services (supervisor training, drafting of materials, providing labor advice, to name just a few) must be reported to DOL and will be publicly disclosed.
Last week the DOL clarified how it will handle agreements entered into BEFORE July 1, 2016. Andrew Auerbach, the Deputy Director in charge of reporting, stated the DOL’s position that:
“Services and payments made pursuant to a multi-year agreement, even if they occur after July 1, are not required to be reported on the new Form LM-20, so long as the agreement was signed prior to July 1.”
Because of this, we believe it is prudent for anyone who may have a future need for indirect persuasion or labor advice to have an agreement on file with us prior to July 1, 2016. This will allow us to provide these services to you under the old reporting rules. This protects your privacy in the future. If you are a prior LRI client we have already sent you a copy of this Agreement. However, for INK subscribers who wish to also have one of these Agreements on file (there is no obligation to do any engagement when you enter this agreement).
If you wish to have one of these Agreements on file please click here we will send you a copy.
For more information on this rule visit the DOL website here.
Feel free to call us with any questions. Our number is 800-888-9115.
The video window below will play the March 31, 2016 Webinar on the final rule.
Download the slide deck from that webinar here.
Download the handout from the webinar here.
Thus far, 3 lawsuits have been filed against the rule, as follows:
- U.S. District Court in Lubbock, TX (5th Circuit) by the National Federation of Independent Business (NFIB), the National Association of Home Builders (NAHB), the Texas Association of Business, the Lubbock Chamber of Commerce, and the Texas Association of Home Builders
- U.S. District Court in Minneapolis, MN (8th Circuit) by a group of management-side law firms - WorkLaw.
- U.S. District Court in Little Rock, AR (8th Circuit) by CDW, NAM and ABC.
If you would like to take advantage of a free 30 minute consultation with Phil about your company’s response plan, click HERE (or e-mail Tammy directly at firstname.lastname@example.org) or call 1-800-888-9115.
Additional resources are available on this page.