Learn more about Member Benefits
Today CUNA filed comments
with the Department of Labor concerning a proposed rule which would raise the
salary threshold for overtime eligibility, from $455 a week ($23,660 a
year) to a projected level of $970 a week ($50,440 a year), by 2016. The
proposal would also establish a mechanism for automatically updating the
minimum salary and compensation levels in the future. In the comment letter, we
argued that the proposed salary threshold for overtime is not appropriate for
credit union employees in general, but may be particularly inappropriate for
small credit unions and those in rural and underserved areas.
A substantial percentage of credit union employees,
specifically employees of smaller credit unions and those in rural or
underserved areas, fall into the salary threshold to be eligible for overtime
pay under the new proposed rule. The comment makes the point that at some
credit unions, even CEOs will fall under the new threshold, and also notes that
since those in management often work over 40 hours a week this could make
overtime costs increase exponentially.
The letter further points out that among
credit unions with less than $10 million in assets, almost all CEOs make less
than $50,000. Among those with $10 to $20 million in assets, roughly half of
CEOs make less than $50,000. Importantly,
46% of all credit union CEOs work at credit unions with $20 million or less in
We also noted that CU employee salaries vary greatly
depending on asset size, location, and number of employees, services offered, members,
and branches. Setting one salary threshold for the entire country overlooks the
fact that the cost of living throughout the country varies, and salaries in
different regions also vary to reflect that. The letter references several
examples where federal rulemakings and policies account for these differences,
and asks the DOL why that same concern is not addressed in the proposed rule.
The letter also outlines several concerns about unintended
consequences the proposed rule—for example less benefits and “perks”, stricter
guidelines on overtime and time off, and fewer opportunities for participation
in out of office events that may be not in the course of a regular workday.
We expressed appreciation to the DOL for attempting to take
steps to improve the livelihood of American middle-class families, a cause that
credit unions have long supported. However, we also believe the DOL’s proposed
rule overlooks a number of important factors outlined in the letter.
result of these insufficiencies, we stated that it was necessary for the DOL to
engage in further analysis about the likely impacts of its proposed rule, and
to more narrowly tailor the proposal to include a more reasonable percentage of
the workforce, that does not include entire industries or regions of the
country. You can read our letter here.
Champion for the Credit Union Movement
Credit Union National Association is the most influential financial services trade association and the only national association that advocates on behalf of all of America's credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.
© 2017 Credit Union National Association
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ADA Compliance Notice & Legal