Overall, the impact of these proposed changes would mean that there might be no exempt employees in some of my locations. Additionally, retail managers who would be reclassified because of the changes might lose incentive compensation opportunities, benefits, flexibility and professional status that they highly value. Managers could also lose opportunities for career progression and training as a result of the change in how they are classified.
On top of these impacts on current salaried workers, we expect that hourly workers would face diminished opportunities for upward mobility as middle-management ranks shrink as a result of the rule. The changes would also negatively impact customer service and prices and could result in retailers looking further to automation. Like most retailers, we face fierce competition and thin profit margins and simply cannot absorb significant volatility, uncertainty and increases in labor costs.
For all of these reasons, I strongly oppose the proposed increase to the salary level, any attempt to annually increase the salary level, and any changes to the duties test. Thank you for considering these views.