SCOPELITIS, GARVIN, LIGHT, HANSON & FEARYRule Agreement • June 27th, 2016
Contract Type FiledJune 27th, 2016As you know from our recent reports, the U.S. Department of Labor has revised the circumstances under which employers and labor relations consultants must file public reports identifying their “persuader” activities. Many of the services provided by our Firm to the Company and its affiliates in the past, such as providing labor advice, supervisor and management training, drafting materials for communications with employees, and the like, would now be covered by this new “indirect persuader” activities reporting requirement. Importantly, however, indirect persuader activities and payments made pursuant to a multi-year agreement to which the parties entered into prior to July 1, 2016, will not be covered by the new regulation. In other words, to the extent parties have an agreement in place prior to July 1, no public reports will need to be filed even if the actual services or payment for such activities and services occurs after July 1.