ABA Staff Analysis Explores DoL Overtime Proposal

ABA yesterday released a bank members-only staff analysis of the Department of Labor’s proposal to revise the requirements for employees to be exempt from overtime pay under the Fair Labor Standards Act.

The proposal would more than double the salary basis test — the level below which all employees must be paid overtime beyond 40 hours per week, regardless of their duties — while increasing compensation requirements for highly compensated employees.

ABA’s staff analysis covers several elements of the proposal, including the salary basis test, annual adjustments, highly compensated employees, non-discretionary bonuses and incentives, duties tests and the effective date. For more information, contact ABA’s Cris Naser.