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Hi Beverly - the DOL has answered this in their fact sheet 22. The quick answer is yes this time must be paid since it is not voluntary, although it may meet some of the other three criteria. See the second paragraph of page 2. More broadly, the FLSA requires payment for work suffered or permitted. ...

HI Kristen, from looking at your firms' website, it appears that you are a financial firm. I would recommend that you find others who are similarly situated and ask them how their firms handle things such as what you are asking about. There is a local accounting firm here in Burlington, VT - Gallagher ...