Tip Pooling: Provide Real World Experience to Federal Decision-Makers

The Department of Labor received nearly 400,000 comments on its proposal to authorize the pooling of tips; the overwhelming number of the comments were in opposition to the proposal.

There is an urgent need to supplement the docket with real  world experiences that document the benefits to be achieved from tip pooling. Normally an Interactive Public Docket (IPD) is used to serve this need. Here is an IPD that the Center for Regulatory Effectiveness, CRE, utilized which attracted  nearly a thousand letters–not form letters– from  only one post. There were a number of other posts that received comments in the hundreds.

The Center for Regulatory Effectiveness has under consideration the development of an IPD dedicated exclusively to the Tip Pooling rule  but in the meantime it is recommend that affected stakeholders provide their experiences  in the comment section below.  Comments may be submitted anonymously.

N. B.  An IPD dedicated to the Tip Pooling rule would:

  • permit respondents to send PDF’s containing relevant information.
  • have discussion forums dedicated to specific subtopics.
  • have a forum dedicated to news coverage of the tip pooling rule.
  • contain detailed analytic studies prompted by the comments performed by CRE.
  • provide for occasional press releases by CRE on the tip pulling rule.

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