Office of General Counsel Memorandum GC 21-06, Seeking Full Remedies (issued Sept. 8, 2021). In a memorandum issued to NLRB field offices, Abruzzo directed staff to seek a variety of new remedies in ULP cases. Currently, monetary remedies for violations of the National Labor Relations Act (NLRA) have been limited to restoring an employee’s actual compensation lost because of an employer’s (or a union’s) ULPs — which is how the Board defined “make whole” relief.