Based upon rumors from informed sources and other indicators, it appears that the DOL is priming the roll-out of the new overtime pay exemption regulations for as early as May 16. For various reasons, not the least significant of which being the Administration’s desire to insulate the new regulations from a possible congressional override per the Congressional Review Act, the conventional wisdom is strongly favoring a mid-May roll-out. If this holds true, the likely effective date will be around July 15, 2016.

Employers should be assessing their options and planning for the change. Under the new regulations, it is anticipated that 4 to 5 million employees will lose their exempt status and become eligible for overtime pay.