That's an excellent description. You got the idea far better than many people do.

The problem is, based on factors I cannot assess from here, I can see it going either way. I lean towards non-exempt but I wouldn't be overly surprised if I were told it was exempt, either.

You may need to contact the DOL to determine your status.

BTW, it was late when I responded last night and I omitted to include that IF you are non-exempt, then any hours over 40 in a work week MUST be paid at time and a half.