Believe me, this is not a "one-size-fits-all" decision. It can depend on several variables, and I cannot recommend basing one bank's decision on what "other banks are doing." You can't make an informed risk-based decision without knowing what the risks are, and that is where you need to talk to an attorney that is well versed in employment and the Labor Department's rules in particular.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8