New DOL Reporting Requirements for Labor Organizations

U.S. Department of Labor issues union transparency final rule

Rule establishes Form T-1 for union trust reporting

As part of the on-going effort to develop a higher level accountability over the way labor union organizations spend member dues, the Department of Labor announced the creation of a new form T-1. Unions will be required to complete this form in addition to the standard LM-2 and other documents they are currently required to file.

The Office of Labor-Management Standards (OLMS) will have administrative responsibility for tracking the documents. The final rule posted on their web site is intended to enhance financial reporting and provides union members with more transparency about how their dues funds are spent by large union trusts.

With meaningful disclosure, the department hopes to deter potential misuse of union trusts that have occurred in the past and allow union members to know exactly where their hard-earned dollars are being spent." said Don Todd, deputy assistant secretary for labor-management programs.

Union trusts are established primarily to provide benefits to union members and their beneficiaries. Some common examples include credit unions, strike funds, redevelopment or investment groups, training funds, apprenticeship programs, building funds and educational funds. The Form T-1 will provide information to union members and the public about these types of trusts, for which there is currently little, if any, financial disclosure.

Under the rule, unions will be required to annually file a Form T-1 for trusts in which a union, alone or in combination with other unions, possesses managerial control or financial dominance.

The Form T-1 will use the same basic template as the existing Form LM-2, which has been in effect since Jan. 1, 2004, and unions have experience with filing. Only labor unions with total annual receipts of $250,000 or more will need to file a Form T-1.

OLMS's public disclosure Web site at http://www.unionreports.gov/ contains union annual financial reports and additional reports required to be filed under the LMRDA as well as copies of collective bargaining agreements.

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