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ERIC Comment Letter to Arizona Industrial Commission Regarding Proposed Rulemaking on Paid Sick Leave (PDF)
The ERISA Industry Committee [ERIC] [Opinion] June 6, 2017
"ERIC respectfully requests that the Proposed Amendments to Article 12 be modified to allow for ... mandating carryover only in instances where the employer does not frontload sick leave. This alternative serves the underlying purpose of the Act, but does so in a way that provides optimum benefits to the employee without burdening employers.... [T]he Proposed Amendments must make clear the types of policies that are covered (e.g. unlimited paid sick leave, unlimited PTO, universal PTO banks, etc.), and whether employers with sufficient policies are exempt from the Act and relevant aspects of Article 12 or whether the exemption is simply applicable to the leave afforded to each employee."
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