Multiple sources have reported that yesterday the USDOL sent the proposed final overtime rule to the Office of Management and Budget (OMB) for its mandatory review.  If OMB’s review is completed on an expedited basis, DOL could disseminate the proposed final rule to the public by mid-April, with an effective date potentially as early as the beginning of June, subject to delay from that date based on Congressional review under the Congressional Review Act.

This announcement moves the anticipated effective date up in time from most prior projections, which placed the date in the third quarter of 2016.  An accelerated timetable may be motivated by political pressures related to the upcoming election and potential changes in the White House and Congress.  Watch this space for further developments.