Comment from Retail Industry Leaders Association (RILA)
Retail Industry Leaders Association (RILA)SupportTrade association
Summary: The Retail Industry Leaders Association (RILA) supports the Department's proposed framework for assessing joint employer status, specifically the adoption of the four Bonnette factors. However, they urge the Department to include specific modifications to strengthen the "actual exercise of control" requirement, exclude economic dependence factors, and include more retail-specific illustrative examples.
We submit these comments on behalf of the Retail Industry Leaders Association ("RILA") and pursuant
to the U.S. Department of Labor Wage and Hour Division's ("WHD" or the "Division") notice of proposed
rulemaking and request for comments regarding Joint Employer Status Under the Fair Labor Standards
Act (the "FLSA"), Family and Medical Leave Act (the "FMLA"), and Migrant and Seasonal Agricultural
Worker Protection Act ("MSPA"), Docket No. WHD-2026-0067 (the "Proposed Rule").