Could December 1 affect a New York City staffing arrangement?
NYC guidance says the direct-employment provisions for core staff apply to hotels with 100 or more rooms, with an exception allowing a single qualifying hotel operator to employ them. For certain contractor agreements executed before May 3, 2025 without a fixed termination date, the transition ends December 1, 2026. (nyc.gov)
Desk action: Have counsel determine applicability and exceptions before approving the 2027 staffing model. Do not assume that a historical outsourcing arrangement remains available indefinitely.
Does the booking journey show mandatory fees correctly?
The FTC’s lodging-fee rule took effect May 12, 2025. It requires covered advertised prices to include mandatory charges, subject to specified exclusions; it is not a prohibition on charging every type of fee. Government charges can be excluded from the initially displayed total under the rule’s conditions. (ftc.gov)
Desk action: Audit representative direct and intermediary booking paths with the operator and counsel. Test actual displays rather than relying solely on a distribution vendor’s assurance.