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The Independent Community Bankers of America (“ICBA”)1 appreciates this opportunity to submit comments in response to the Department of Labor’s (“DOL”) proposed changes to the exemptions from minimum wage and overtime pay requirements for executive, administrative, professional, outside sales, and computer employees.
ICBA believes that the proposed changes exceed DOL’s authority, and in any event, would impose significant additional labor costs on community banks that would result in layoffs and hourly wage reductions for executive, administrative, and professional employees.