Eleventh Circuit Holds Title Insurance Executive Who Conducts "Promotional Work" Exempt Under the FLSA "Outside Sales" Exemption

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The Eleventh Circuit Court of Appeals rules that the “outside sales” exemption to the FLSA overtime requirements was properly applied to an executive for a title insurance company whose primary duty was conducting “promotional work” with the company’s clients, even though the employee did not finalize sales herself. According to the court, the executive, who was credited with sales through commission-based compensation, was conducting “sales in some sense.”

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