On Monday, April 16, 2012, the Michigan Office of Regulatory
Reinvention ("ORR") released recommendations to
deregulate 18 occupations in Michigan and to eliminate 9
occupational boards. Included in the occupations for which the ORR
recommends deregulation are professional employer organizations
("PEOs"), which became subject to state licensure in
January 2012. It is unclear at this time whether and when the
newly-adopted Michigan Professional Employer Regulatory Act will be
The ORR made 63 recommendations "for improving
Michigan's occupational licensing relations" in addition
to recommending the rescission of all or part of 23 separate
occupation rules and revising and amending many more. Governor
Snyder has reviewed the ORR's recommendations, and the ORR, in
conjunction with the Department of Licensing and Regulatory Affairs
("LARA"), will work toward implementing the
The 18 occupations recommended for deregulation are:
Consumer Finance Services
Dieticians & Nutritionists
Forensic Polygraph Examiner
Immigration Clerical Assistant
Professional Employer Organizations
Proprietary School Solicitors
Security Alarm Contractors
Vehicle Protection Product Warrantor
The 9 occupational boards recommended for elimination are:
Clients engaged in or connected with the affected occupations
should be aware of the new recommendations and should ask Dickinson
Wright whether there are any enacted laws or regulations affecting
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guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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