Last week, the U.S. Department of Labor (DOL) issued a final rule that requires employers to report agreements they have made with outside consultants to craft anti-union messages to workers. As a general matter, the LaborManagement Reporting and Disclosure Act (LMRDA) requires disclosure of financial transactions and administrative practices of labor organizations and employers, including when employers engage outside labor relations consultants to persuade employees about their union activities or to supply certain information to the employer. Prior to the controversial “persuader rule,” the “advice exemption” in Section 203(c) of the LMRDA excluded from the reporting requirements circumstances where labor relations consultants provided advice but did not have direct contact with employees. With the adoption of the persuader rule, this exemption will be narrowed, and employers will now be required to report even indirect communications between labor relations consultants and employees regarding their collective bargaining rights.