OT proposal improved, but DOL should not create burdens for CUs

May 23, 2019


May 22, 2019 

Credit Union National Association (CUNA) responded to the Department of Labor’s (DOL, Department) overtime regulation proposal under the Fair Labor Standards Act (FLSA). CUNA urges the DOL to further consider how the current proposal would create excessive costs and compliance burdens for credit unions.  

“The proposal attempts to strike a balance between ensuring the salary level test is consistent with present day practice while also avoiding a sudden jolt to the resources of small employers,” CUNA Senior Director of Advocacy & Counsel Alexander Monterrubio writes. “CUNA agrees the proposal provides a more sensible balance of those two goals than the 2016 Overtime Rule, which we expressed serious concern about at the time." 

The 2016 Overtime Rule increased the salary level for overtime exemption to $47,476 annually (up from $23,660 annually). While the current proposal is more modest in comparison, CUNA maintains that the proposed regulation has the potential to burden small financial institutions as well as those located in rural or underserved areas.  

“The Department’s proposed increase in the salary level threshold for an employee to qualify for the “white collar” exemption is modest compared to the 2016 Overtime Rule, but even modest increases have the potential to strain small credit unions’ finite resources.” 

CUNA is concerned about the negative effect the rule will have on smaller credit unions and those in rural or underserved areas, as well as with a “one-size-fits-all” national standard for salaries. 

Read the letter in full here 


About CUNA:        
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit  


Lauren Williams      
CUNA Communications