NA, Turner, James

I am writing to express my opposition to the Labor Department's proposal and to urge you to withdraw it.
The proposed changes impose no new requirements on labor unions, but radically expand reporting and disclosure requirements on employers. They are so broad that much that routine legal advice will now be subject to disclosure. The proposal will have the effect of making it harder for employers to find counsel during a union campaign and are a thinly veiled attempt to give unions the upper hand.
The Labor Department should focus on creating an environment that will lead to economic growth and job creation. This proposal will not create one new job, but will instead impose greater burdens on employers making it even harder for them to focus on growing their businesses and creating jobs.
For these reasons, I urge the Labor Department to withdraw the proposed changes to the "advice" exemption.