NLRB Postpones Deadline For Posting Notice

The National Labor Relations Board announced recently its decision to postpone the implementation date for its new notice-posting rule. Previously, the Board's new notice-posting rule required employers to post the 11x17 inch poster no later than November 14, 2011. That date has been delayed until January 31, 2012.

In a press release, the Board indicated that the rule's effective date was delayed "by more than two months in order to allow for enhanced education and outreach to employers, particularly those who operate small and medium sized businesses." The Board indicated that it had received a number of questions from business and trade organizations that suggested uncertainty about which businesses are covered by the new requirement.

Other than the effective date, no other changes in the rule, or in the form or content of the notice, will be made.

Come and knock on our door. . .

As I read this latest article from SHRM this morning, the theme from "Three's Company" popped into my head. Yes, indeed, we've been waiting for you.

Seems as though federal governmental agencies may be sharing information to determine who will receive or has received ICE audit notices. According to the article, companies which found themselves the subject of an investigation or audit from another agency--mostly related to the employment of immigrants--also received a heads-up that ICE would be coming to inspect their Form I-9s.

As we recommended (okay, whined) earlier here, the time to look at your Form I-9s for compliance issues is long before you even think you might be getting an audit letter. And if you do find yourself on the mailing list of any government agency, please engage counsel as soon as you receive the letter and before you provide anything in response to the notice.