Amy DeBisschop
Division of Regulations, Legislation, and Interpretation
Wage and Hour Division
U.S. Department of Labor
Room S-3502
200 Constitution Avenue NW
Washington, D.C. 20210
RE: Comments Submitted on Behalf of the National Employment Lawyers Association on Notice of Proposed Rulemaking RIN 1235-AA31
Dear Ms. DeBisschop:The National Employment Lawyers Association (NELA) submits these comments to the Notice of Proposed Rulemaking by the United States Department of Labor (“the Department”) regarding the Fair Labor Standards Act of 1938 (“FLSA”), issued for comment on November 5, 2019 at 84 Federal Register 214, et seq. (the “2019 NPRM”).
NELA is the largest professional membership organization in the country comprised of lawyers who represent employees in labor, employment, wage and hour, and civil rights disputes. Founded in 1985, NELA and its 69 circuit, state, and local affiliates have a membership of over 4,000 attorneys who are committed to working on behalf of those workers who have been treated illegally. NELA strives to protect the rights of its members’ clients, and regularly supports precedent-setting litigation affecting the rights of individuals in the workplace. NELA has a compelling interest in seeing that the goals of the FLSA are realized. To