The Clearing House Association (TCH), along with the FSR, ICBA, MBA and ABA (the Trades), filed a comment letter with the Department of Labor (DOL) on its proposed rulemaking to change overtime compensation requirements for certain employees. The Trades believe that with certain changes, the DOL’s rulemaking can be much more consistent with the DOL’s “commitment to a 21st-century regulatory system.” A summary of the Trades proposed changes are as follows: to the extent that a process for adjustment in the salary levels is adopted, it should account for administrative burdens; the salary level for exemption should be set in recognition of the substantial regional variations in compensation; all bonuses and incentive payments should count toward the salary level; the duties tests for Highly Compensated Employees should be eliminated; avoid changes to the primary duties test that could increase rather than reduce costly and unnecessary litigation, and that would deprive the public of an opportunity to assess in detail; and employers should be given an appropriate amount of time to comply with any rule once final.