The Association of Corporate Counsel (“ACC”) and its Employment and Labor Law Network fully support the National Labor Relations Board’s (NLRB) proposed rule on The Standard for Determining Joint-Employer Status. We appreciate the Board’s willingness to establish a rule in light of the instability caused by the Browning-Ferris ruling and subsequent procedural developments. We approve of the proposed standard as written because it provides a simple and fair standard by which companies can determine the existence of an employment relationship.