It never even went into effect because implementation was permanently enjoined by the federal court in Texas, but the Obama administration’s so-called persuader rule is well on the way to being completely and formally erased by the Department of Labor. Recall that the persuader rule imposed strict reporting measures on employers when they were dealing with union representation elections and essentially stripped them of attorney-client privilege in cases where the attorney was working to defeat a union election. Well, this week the Department submitted a proposed rule to OMB (the Office of Management and Budget) that will permanently rescind the union-favoring persuader rule. Once OMB approves the rescission rule, it will be published in the federal register, triggering a public comment period. At the conclusion of the period, the DOL will complete the process and formally adopt the rescission.