Are 'managers in training' exempt from OT?

Most managers are exempt from overtime payment under the FLSA. But what about employees getting trained to become managers?
The Department of Labor tackled that question in a recent Opinion Letter. A company asked about this scenario:
A group of store managers were selected to be trained for a possible promotion to district manager positions. Both store manager and area manager are exempt jobs.
But during most of the seven-week training course, the employees performed mostly nonexempt work while they shadowed an existing area manager. The amount of hands-on management (i.e., exempt work) they performed increased as the training progressed.
So the company asked the DOL: Do those employees lose their exempt status during training?
The answer: No.
The Opinion Letter noted that the executive exemption doesn’t apply to nonexempt employees who are training for, but haven’t yet assumed, an exempt position. In other words, a nonexempt employee training to be a manager wouldn’t become exempt during the training.
But in this case, the employees are already exempt. And, the DOL said, attending training doesn’t change the store managers’ primary duty. They’re still employed as store managers, which is an exempt position in this case.
Read the Opinion Letter from the DOL here.