Back to blog
1 min readBy ACWI

Opinion Letters Offered by DOL

The Trump Department of Labor has begun issuing opinion letters to employers regarding the laws that govern wages and working conditions, which had been a common practice before it was suspended during the Obama administration. From 2010 to July 2017,…

The Trump Department of Labor has begun issuing opinion letters to employers regarding the laws that govern wages and working conditions, which had been a common practice before it was suspended during the Obama administration.

From 2010 to July 2017, opinion letters were replaced by “Administrator Interpretations,” which set forth a more general interpretation of the law and regulations as they pertained to a particular industry or grouping of employees.

Although revival of the employer letter practice was announced in June 2017, the DOL Wage and Hour Division had yet to issue any until last month.

The Trump DOL’s initial action was to reinstate 17 opinion letters that had been published in January 2009 during the final weeks of the George W. Bush administration, which then were immediately withdrawn by Obama’s factotums soon after the new President took office.

The 17 re-released opinion letters address a wide variety of topics under federal wage law, including white collar exemption issues, the compensability of certain on-call time, some rate and overtime computations on certain bonus compensation, and certain deductions from salary under the salary basis requirements of the white-collar exemptions.

“Employers generally applaud the return of opinion letters because they provide greater clarity for businesses by publicly answering fact-specific questions,” observes attorney Stefan M. Canizares of the law firm of Foley & Lardner LLP.

The letters can be particularly useful for employers who find themselves dealing with factual scenarios similar to those covered by the letters, he notes.

One thing that may hinder the flow of these letters in the immediate future is that the DOL Wage and Hour Division currently lacks an administrator.

Although the President nominated Cheryl Stanton, who heads the South Carolina Department of Employment and Workforce, she has yet to be confirmed by the Senate.

Originally published March 2, 2018 · updated March 22, 2023.

Related reading

Browse all posts →
4 min

ACWI Spotlight: June 2026

WELCOME JUNE! Chris Kane will be attending the Summer Fancy Food Show in New York City at the end of June. We are excited to share two outstanding resumes with the Xchange Board, welcome Jose Larenas as Strategy & Operations Lead, and cover manufacturing renaissance, IWLA's 3PL impact study, cargo theft recovery, and more…

7 min

ACWI Spotlight: May 2026

HELLO MAY! Dear Members, We welcome May with a lot of global uncertainty — the tariffs that were imposed are now in the process of refunding, oil prices are at record highs, and the four-year transportation recession seems to be behind us. Manufacturing is coming back to America, Mexico just passed China as the #1 exporter to the U.S., and our team is positioning members to take advantage of both shifts…

5 min

ACWI Spotlight: April 2026

WELCOME SPRING! Dear Members, I know many of our members are welcoming Spring after a long hard winter. As you are reading this, I am attending the IWLA Conference in San Antonio, Texas. The IWLA is actually 20 years older than us and is the oldest Warehouse…