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Counsel Opinion Letters

These opinions represent the views of the Department at the time they were rendered. The opinions may no longer represent those views if, for example, there have been subsequent court cases or statutory amendments that bear on the issues discussed in the opinions. Opinions are no longer rendered by the Department of Labor.

Opinions obtained from the Department were given based on the representation, express or implied, that the requestor provided a full and fair description of all the facts and circumstances that would be pertinent to the Department's consideration of the question presented. Existence of any other factual or historical background not contained in the information provided may require a conclusion different from the one expressed in the opinion.