Executive Summary: 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 respond to this email with YES and we will send you 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 all LRI clients who may have a future need for indirect persuasion or labor advice to have an agreement on file 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 respond to this email with YES and we will send you a copy.
For more information on this rule, check out our website here or the DOL website here.
Feel free to call us with any questions. Our number is 800-888-9115.
P.S. I know we all get too much email, so please accept my apology about the multiple emails about this. Given the urgent nature of this request, we are sending to people who may be on multiple lists. Thanks so much for your understanding. |
