Update - DOL's Final White Collar Exemption Rule Could Be Published Earlier Than July 2016

As discussed in our February 17 Alert, employers should be prepared for implementation of the U.S. Department of Labor's (DOL) Final Rule revising its White Collar Exemption Regulations.  While it appeared from comments made at the American Bar Association's (ABA) Midwinter Meeting of the Federal Labor Standards Legislation Committee that the Final Rule should be published in July 2016, DOL Solicitor of Labor M. Patricia Smith later clarified that the Final Rule could be published in or before July and will take effect at least 60 days later. 

While FordHarrison still predicts that the regulations will be published in early July, the Final Rule may be published before July 2016, making it even more important for employers to prepare for the implementation of the Final Rule. In light of the significant impact of the Rule on most companies, employers should begin taking steps now to ensure they will be in compliance with the Final Rule when it takes effect.