An unnamed trade association doesn't have to pay its paralegals overtime because they are already highly paid and are administrative workers, the Department of Labor says in an opinion letter. These two factors would make them "exempt" from receiving overtime pay under the Fair Labor Standards Act, in the agency's terminology.

The paralegal or paralegals received total annual compensation of at least $100,000—the threshold for an overtime exemption for certain employees.

Although the name of the "global trade organization" is redacted from the version of the letter posted publicly online, there may be a clue in the text. One duty of the paralegals involved is to "prepare and submit music licensing and annual state registration reports," according to the opinion letter, citing the query submitted to the agency.

DOL opinion letters are based solely on the facts submitted in the query and are not meant to serve as general rulings. They were issued frequently during the administration of George W. Bush, discontinued during the Obama administration, and have been revived in the Trump administration.

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