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We ask for your review of an unformatted, review draft of a letter in support of DOL's proposed FLSA employee/independent contractor classification rule. The
rule would rescind the employer-friendly, Trump-era FLSA classification
rule that was promulgated in January 2021 at the eleventh hour,
replacing it with the six-factor economic reality test that has long
been relied on by the courts.
You can view and comment on the review draft here: https://docs.google.com/document/d/1ftxLt0u1NPd9u_hoi5DI7rM1dFtWypcSe1QRGxnZy_A/edit?usp=sharing
You'll
see with our draft letter that we aimed to stay broad in our
support, focusing on the importance of proper employee classification
for creative professionals. (The AFL-CIO plans to submit a much more
detailed comment that gets into the specifics of the economic reality
test.)
Comments are due to DOL by December 13th. Please provide any feedback and let us know if your union is okay with the letter by COB Monday, December 12th. (The letter will be signed by Jennifer on letterhead that includes the logos of participating AEMI unions.)
Here is the Federal Register notice for the proposed rule. NELP's explainer is attached.
As always, please let us know if you have any questions.
