The Department of Labor’s recently-issued Final Rule, 81 Fed. Reg. 15924 (the “Persuader Rule”) imposes upon employers and their advisors (including lawyers and consultants), for the first time, the obligation to file public reports with the DOL disclosing any advice that “indirectly persuades” employees regarding union organizing or collective bargaining.1 Prior to the Persuader Rule, such reports were required only when an advisor made direct contact with the employer’s employees, regardless of the persuasive purpose of the advice. The published rule provides that it will become effective on April 25, 2016, and apply only to “persuader” arrangements and agreements, as well as payments (including reimbursed expenses) made on or after July 1, 2016.
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