In Whalen v. J.P. Morgan Chase & Company, the federal Second Circuit Court of Appeals reversed the dismissal of an overtime lawsuit ruling that a loan underwriter was not exempt from overtime under FLSA. The employer urged that plaintiff, an underwriter in the bank’s home equity group, was covered by the administrative exemption. However, the court ruled that the job of underwriting loans was “production” work, unrelated to setting management policies or general business operations necessary for the FLSA’s administrative exemption.