Proposed increase to salary levels for white collar exemptions


On June 30, 2015, the United States Department of Labor (DOL) announced its proposals for updating its regulations to increase the base salary levels for the overtime exemptions for white-collar employees, such as executives, administrative and professional employees.  Because the DOL invited interested parties to submit written comments on the proposed rules by September 4, 2015, it was widely anticipated that any new regulations would go into effect as early as January 2016.  However, the DOL received more than 290,000 comments on the proposed rules, requiring a more thorough examination of the possible impact of the proposed rules.

On November 11, 2015, the Wall Street Journal reported that during a panel discussion at the recent American Bar Association’s Labor and Employment Conference, DOL Solicitor Patricia Smith indicated that the final rules will not likely be published before late 2016.  The delay was due to the volume of the comments, and the complex nature of the proposed changes.  This delay will give employers additional time to determine what changes need to be made within the organization.

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  • Shannon Hamilton is a member at Stites & Harbison in Louisville, Ky.