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It depends on exactly what the job duties are. If the person does not normally perform any duties requiring independent judgment but merely ensures the rules of the college are followed and does filing (i.e. the "counselor" part of the title is really a misnomer and they're essentially a clerk), then no. If, however, they are routinely required to exercise their own judgment on whether students get admitted or not and are not merely applying a set of predetermined rigorous rules, then they would be exempt.

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