One thing is clear about Secretary of Labor Thomas Perez: He interprets laws creatively to give himself the widest possible latitude in using the powers of his office. He showed this as the assistant attorney general for civil rights with his fondness for a particularly expansive concept of “disparate impact” theory, the view that intent is not required to prove discrimination.

With that in mind, as well as Perez’s rabidly pro-union outlook, here’s what to expect when the Labor Department releases its “persuader” rule in November: Under Perez, the rule could be used effectively as a pretext to stop most, if not all, labor law attorneys from advising management. Under current law, companies must disclose when they hire labor law consultants during workplace organizing drives, who they are, how much they are being paid and so forth.