The Clearing House (TCH) along with the Financial Services Roundtable and the Mortgage Bankers Association filed a response to the Department of Labor’s request for information on its overtime pay rule. The letter asserts that: using a uniform nationwide salary test promotes simplicity and reduces administrative burden; permitting all bonuses and incentive payments to count toward salary levels is appropriate; avoiding automatic updating to the salary level helps ease compliance burdens; and modernizing the test for highly compensated employees makes sense, as does permitting part-time employees to satisfy a prorated salary-level test.
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