As we reminded last week, the Department of Labor has been scheduled to publish a final rule this month amending their "persuader regulations" and imposing new and expansive reporting requirements on employers, their labor relations consultants and, very likely, their attorneys.

Former DOL economist Diana Furchtgott-Roth just issued a report from the Manhattan Institute estimating the cost of the proposed changes. Ms. Furchtgott-Roth estimates that the cost of the revisions to its long-standing interpretations at $7.5 billion to $10.6 billion in the first year of implementation, and as much as $6.5 billion annually after that. This differs significantly from the Administration’s estimates of $826,000 per year. Ms. Furchtgott-Roth notes the Administration’s figure "falls below the level required for mandatory cost-benefit review.”