NOTE TO REVIEWER

OMB No. 1245-0003

This submission is considered a revision of an existing collection, as the information 

requirements of the Labor-Management Reporting and Disclosure Act (LMRDA) are 

currently approved under OMB # 1245-0003, with an expiration date of August 31, 

2016. The currently approved collection includes Forms LM-1, LM-2, LM-3, LM-4, LM10, LM-15, LM-15A, LM-16, LM-20, LM-21, LM-30, and S-1. 

This revision is necessary since the Department seeks to revise the instructions to the 

Form LM-3 and LM-4 Labor Organization Annual Reports, in order to mandate 

electronic filing, as well as amend the hardship exemption process for Form LM-2 filers.

The Department notes that it has a pending rulemaking concerning two of the reports 

included in the Labor Organization and Auxiliary Reports information collection: the 

Form LM-10 Employer Report and the Form LM-20 Agreement and Activities Report 

filed by labor relations consultants. See 76 FR 37292 (June 27, 2011). The 

Department received comments on those estimates during the rulemaking, and it will 

respond to such comments in any final rule issued, as well as in any request for 

amendment to the information collection submitted to OMB in the context of that 

rulemaking. 
PAPERWORK REDUCTION ACT

EMPLOYER AND AGREEMENT AND ACTIVITIES REPORTS

SUPPORTING STATEMENT

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the 

collection. Attach a copy of the appropriate section of each statute and 

regulation mandating or authorizing the collection of information.

Congress enacted the Labor-Management Reporting and Disclosure Act (LMRDA), 

29 U.S.C. 401 et. seq., to provide for the disclosure of information about the financial 

transactions and administrative practices of labor organizations. The statute also 

provides, under certain circumstances, for reporting by labor organization officers and 

employees, employers, labor relations consultants, and surety companies. In addition, 

the statute requires: (a) the maintenance and retention of supporting records for five 

years after the required reports are filed, and (b) the preservation for one year of 

records of elections of labor organization officers. Section 208 of the Act authorizes the 

Secretary of Labor to issue rules and regulations prescribing the form of the required 

reports and such other rules and regulations (including rules prescribing reports 

concerning trusts in which a labor organization is interested) as may be necessary to 

prevent circumvention or evasion of the reporting requirements. 

The LMRDA reporting provisions were devised to protect the basic rights of labor 

organization members and to guarantee the democratic procedures and financial 

integrity of labor organizations. The 1959 Senate report on the version of the bill later 

enacted as the LMRDA stated clearly, “The members who are the real owners of the 

money and property of the organization are entitled to a full accounting of all 

transactions involving their property.” S. Rep. No. 86-187, at 8 (1959), reprinted in 1 

NLRB, Legislative History of the Labor-Management Reporting and Disclosure Act of 

1959 at 397, 404 (1959). A full accounting was described as “full reporting and public 

disclosure of labor organization internal processes and financial operations.” 

The LMRDA applies to labor organizations with private sector employees working in 

interstate commerce within the meaning of sections 3(i) and (j) of the LMRDA, 29 

U.S.C. 402(i) and (j), and labor organizations composed of U.S. Postal Service 

employees. Labor organizations that represent employees of the executive branch 

agencies of the Federal Government, the Library of Congress, the Government Printing 

Office, and certain employees of the U.S. Congress are subject to the standards of 

conduct requirements of the Civil Service Reform Act (CSRA), 5 U.S.C. 7120, the 

Foreign Service Act (FSA), 22 U.S.C. 4117, or the Congressional Accountability Act of 

1995 (CAA), 2 U.S.C. 1301. These latter Acts and the implementing regulations at 29 

CFR 457.10-.20 provide that, in administering the standards of conduct, the Department

will be guided by the interpretations and policies followed by the Department of Labor in 

applying provisions of the LMRDA. In addition, the regulations specifically incorporate 

2
by reference the LMRDA reporting and record retention requirements of all LMRDA 

reports, as well as the requirement for the preservation of election records. Instructions 

for the forms mention corresponding recordkeeping requirements.

The following is a list of the reporting forms, their regulatory and legislative citations, 

and a brief description of each form's usage. 

LM-1, Labor Organization Information Report, 29 CFR 402, 29 U.S.C. 431(a). All 

labor organizations are required to file an initial Form LM-1 concerning the organization 

and its governing rules, including copies of its constitution and bylaws, within 90 days 

after it becomes subject to the LMRDA, CSRA, FSA, or CAA. Labor organizations are 

also required to file an amended Form LM-1 to report certain changes to this information 

when they file the annual financial report. 

LM-2, Labor Organization Annual Report, 29 CFR 402.5 and 403.3; 29 U.S.C. 

431(b). Any labor organization whose total annual receipts are $250,000 or more and 

any organization in trusteeship must file an annual financial report on Form LM-2 within 

90 days after the end of its fiscal year, to disclose its financial condition and operations 

for the preceding fiscal year. This reporting form is also used by such labor 

organizations to file a terminal report if they cease to exist. This report must be filed 

electronically.

LM-3, Labor Organization Annual Report, 29 CFR 402.5 and 403.4; 29 U.S.C. 

431(b). Any labor organization that is not in trusteeship whose total annual receipts are 

less than $250,000, but $10,000 or more may elect to file the simplified Form LM-3

annual report. Labor organizations qualified to use this form may also use it to file the 

required terminal report if they cease to exist. Currently this form, as well as the LM-4, 

may be filed electronically or manually.

LM-4, Labor Organization Annual Report, 29 CFR 402.5 and 403.4; 29 U.S.C. 

431(b). Any labor organization that is not in trusteeship whose total annual receipts are 

less than $10,000, may elect to file the abbreviated Form LM-4 annual report. Labor 

organizations qualified to use this form may also use it to file the required terminal 

report if they cease to exist. 

LM-10, Employer Report, 29 CFR Part 405, 29 U.S.C. 433(a). Any employer, who in 

any fiscal year has made certain payments to or other financial arrangements with a 

labor organization, its officers, its agents or its employees; payments to employees for 

the purpose of causing them to persuade other employees with respect to their 

bargaining and representation rights; payments for the purpose of interfering with 

employees in the exercise of their bargaining and representation rights or for obtaining 

information on employee or labor organization activities in connection with labor 

disputes involving their company; and arrangements (and payments made under these 

arrangements) with a labor relations consultant for the purpose of persuading 

employees with respect to their bargaining and representation rights, or for obtaining 

information concerning employee activities in a labor dispute involving their company is 

3
required to file an annual report on Form LM-10 within 90 days after the end of its fiscal 

year. 

LM-15, Trusteeship Report, 29 CFR Part 408, 29 U.S.C. 461. Any labor organization 

that assumes a trusteeship over a subordinate labor organization is required to file an 

initial Form LM-15 within 30 days after imposition of the trusteeship. Any labor 

organization required to file the initial trusteeship report is required to file a semi-annual 

report on Form LM-15 during the continuance of the trusteeship. 

LM-15A, Report on Selection of Delegates and Officers, 29 CFR Part 408, 29 U.S.C. 

461. Any labor organization that assumed a trusteeship over a subordinate labor 

organization and filed a semiannual or terminal trusteeship report is also required to file 

a Report on Selection of Delegates and Officers on Form LM-15A if, during the period 

covered by the report, there was any: convention or other policy-determining body to 

which the subordinate labor organization sent delegates or would have sent delegates if 

not in trusteeship; or election of officers of the labor organization which imposed the 

trusteeship over the subordinate labor organization. 

LM-16, Terminal Trusteeship Report, 29 CFR Part 408, 29 U.S.C. 461. Any labor 

organization that has assumed a trusteeship over a subordinate labor organization is 

required to file a terminal trusteeship report on Form LM-16 within 90 days after the 

termination of the trusteeship along with a terminal trusteeship financial report on Form 

LM-2. 

LM-20, Agreement and Activities Report, 29 CFR Part 406, 29 U.S.C. 433(b). Any

labor relations consultant or other person or organization that makes an agreement or 

arrangement with an employer to undertake activities with the object to persuade 

employees how to exercise their right to organize and bargain collectively or to supply 

an employer with information concerning the activities of employees or a labor 

organization involved in a labor dispute with the employer is required to file a report on 

Form LM-20 on the nature of the agreement and specific details on the activity to be 

performed. Form LM-20 must be filed within 30 days after entering into the agreement. 

LM-21, Receipts and Disbursements Report, 29 CFR Part 406, 29 U.S.C. 433(b). 

Any labor relations consultant or other person or organization required to file the 

preceding agreement and activities report (Form LM-20) must also file a Form LM-21 

report of receipts from employer(s) and disbursements made by the filer in connection 

with labor relations advice or services provided to employer(s) for any fiscal year during 

which payments were made or received as a result of the reportable agreement or 

arrangement. The Form LM-21 report is required to be filed within 90 days after the end 

of the fiscal year. 

LM-30, Labor Organization Officer and Employee Report, 29 CFR Part 404, 29 

U.S.C. 432. Any labor organization officer and employee (other than an employee 

performing exclusively clerical or custodial services) is required to file a Form LM-30 

4
within 90 days after the end of his/her fiscal year if during that year the officer or 

employee received certain payments from, or had certain interests in:

(1) an employer whose employees the official’s labor organization represents or 

actively seeks to represent; or

(2) an employer or a labor relations consultant to an employer that (a) is in 

competition with an employer whose employees the official’s labor organization 

represents or is actively seeking to represent, (b) is a trust in which the official’s labor 

organization is interested, (c) is a not-for-profit organization that receives or is actively 

and directly soliciting money, donations, or contributions from the official’s labor 

organization, (d) is a labor organization that: (i) has employees the official’s labor 

organization represents or is actively seeking to represent, (ii) has employees in the 

same occupation as those represented by the official’s labor organization; (iii) claims 

jurisdiction over work that is also claimed by the official’s labor organization; (iv) is a 

party to or will be affected by any proceeding in which the official has voting or 

policy-influencing authority; or (v) has made a payment to the official for the purpose 

of influencing the outcome of an internal labor organization election; or (e) has 

interests in actual or potential conflict with the interests of the official’s labor 

organization or the official’s duties to the labor organization; or

(3) any employer for the purpose of (a) not organizing employees; (b) influencing 

employees in any way with respect to their right to organize; (c) taking any action with 

respect to the status of employees or others as members of a labor organization; (d) 

taking any action with respect to bargaining or dealing with employers whose 

employees the official’s labor organization represents or is actively seeking to 

represent; or (e) influencing the outcome of an internal labor organization election; or

 (4) a business (for example, a vendor or a service provider) that meets any of the 

following conditions: (a) 10% or more of its business consists of buying or selling or 

otherwise dealing with an employer whose employees the official’s labor organization 

represents or is actively seeking to represent, (b) any part of its business consists of 

buying or selling or otherwise dealing with the official’s labor organization, or (c) any 

part of its business consists of buying or selling or otherwise dealing with a trust in 

which the official’s labor organization is interested.

 

S-1, Surety Company Annual Report, 29 CFR Part 409, 29 U.S.C. 441. Each surety 

company that issues a bond required by Section 502 of the LMRDA or Section 412 of 

the Employee Retirement Income Security Act (ERISA) is required to file a report within 

150 days after the end of its fiscal year describing its bonding experience under the 

Acts. The report provides for detailed information on premiums, loss data, and specific

items of losses occurring during the report year. 

Simplified Annual Report Format (SAFR), 29 CFR Part 403, 29 U.S.C. 431(b). 

Extremely small labor organizations (those with no assets, liabilities, receipts or 

disbursements during the fiscal year) are permitted to have their parent national or 

international labor organization file the annual financial report on their behalf in a 

simplified format.

5
2. Indicate how, by whom, and for what purpose the information is to be used. 

Except for a new collection, indicate the actual use the agency has made of 

the information received from the current collection.

Pursuant to §205 of the LMRDA, the purpose of the reporting requirements is the public 

disclosure of administrative information and financial reports for covered labor 

organizations, labor organization employees and officers, employers, labor relations 

consultants, and other entities. The information supplied on the reports is used

primarily by 1) labor organization members to participate in the governance of their 

labor organizations; 2) workers in making determinations regarding the exercise of their 

protected rights to organize and bargain collectively; 3) the Department of Labor and 

other government agencies to detect improper practices on the part of labor 

organizations, their officers, and/or representatives and other filers; and 4) the Congress 

in oversight and legislative functions. The general public, the media, and researchers 

may also use the information for their own purposes.

Violations of Title II and Title III LMRDA reporting requirements may be subject to civil 

action by the Secretary of Labor or may be referred to the Department of Justice for 

appropriate criminal action. Certain receipts or transactions reported may also involve 

violations of other Federal laws and may be referred to the Department of Justice for 

appropriate criminal action.

Since June 2002, an Internet Web site (www.unionreports.gov) makes it possible for 

anyone to view labor organization annual financial reports, conduct data searches, and 

display the results in a number of user-definable reports, free of charge. Individuals can 

view and print facsimiles of reports for year 2000 and later, and the reports are 

searchable by a variety of criteria, including labor organization name, file number, 

affiliation, designation name and number, and location. The Department’s Office of 

Labor-Management Standards (OLMS) Web site (www.olms.dol.gov) also features a 

powerful search system where users can search for specific labor organizations. Users 

can obtain information about labor organization officers and employees and payers and 

payees, define the scope of the search to be conducted, and generate a number of 

reports using the search results. Users can also download archive files that contain raw 

data in pipe delimited format of labor organization financial information as reported for 

public disclosure.

Reports filed by employers, labor relations consultants, and labor organization officers 

and employees for year 2000 and later can also be viewed at the Web site and earlier 

reports can be ordered there. 

Copies of every report submitted are also maintained for public inspection and copying, 

upon request, at the U.S. Department of Labor, Room N-1519, 200 Constitution 

Avenue, NW, Washington, D.C. 20210. OLMS receives approximately 281 requests 

per month for public disclosure of reports.

6
3. Describe whether, and to what extent, the collection of information involves 

the use of automated, electronic, mechanical, or other technological collection 

techniques or other forms of information technology, e.g., permitting 

electronic submission of responses, and the basis for the decision for 

adopting this means of collection. Also, describe any consideration of using 

information technology to reduce burdens.

The Department has developed an Electronic Labor Organization Reporting System 

(e.LORS) that utilizes electronic technology to receive, maintain, and disclose the 

information collected under the LMRDA. The objectives of the e.LORS system include 

permitting the electronic filing of Form LM-2, LM-3, LM-4, and LM-30; disclosure of 

reports via a searchable Internet database; improving the accuracy, completeness and 

timeliness of reports; and creating efficiency gains in the reporting system. Effective 

use of the system reduces the burden on reporting organizations, provides increased as

well as more accessible and more timely information to labor organization members, 

and enhances LMRDA enforcement by the Department. 

The Government Paperwork Elimination Act, 44 U.S.C. 3504 (codified in note), requires 

public agencies to provide the public with the option of maintaining, submitting, or 

disclosing required information collections electronically when practicable. The 

Department has developed the Electronic Forms System (EFS), which is a web-based 

system that permits filers to complete and submit Form LM-2, LM-3, LM-4, and LM-30

electronically. The Department intends to update its reporting system to enable all 

forms to be submitted electronically in the coming years. Currently, only the Form LM-2 

filers are required to file electronically, although the Department, through this ICR 

revision, is seeking to expand this mandate to Form LM-3 and LM-4 filers.

4. Describe efforts to identify duplication. Show specifically why any similar 

information already available cannot be used or modified for use for the 

purposes described in Item A.2 above.

Other than certain financial data received by the Internal Revenue Service (IRS), there 

is no duplication of existing labor organization reporting requirements, nor is similar 

information required by any other federal agency or statute.

To prevent duplication with the forms, a labor organization is not required to report a 

Political Action Committee (PAC) fund, if publicly available reports on the PAC's funds 

are filed with federal or state agencies. 

The Form LM-30 requires labor organization officers and employees to report certain 

payments from employers. Form LM-10 requires employers to report, among other 

matters, certain payments to labor organization officers and employees and certain 

agreements and activities involving labor relations consultants. Forms LM-20 and LM21 require labor relations consultants to report certain agreements with employers and 

payments pursuant to such agreements. This results in some duplicate reporting, a 

7
result mandated by Congress in designing parallel reporting schemes to facilitate 

compliance and public disclosure. See 29 U.S.C. §§ 432, 433. 

5. If the collection of information impacts small businesses or other small 

entities, describe any methods used to minimize burden.

OLMS reduces burden where practicable and where transparency goals would not be 

sacrificed. For example, the Forms LM-3 and LM-4 are less detailed than the Form LM2 (the latter filed by the largest labor organizations) and the SAFR allows a parent 

national or international labor organization to file a simplified annual financial report on 

behalf of certain extremely small affiliated labor organizations.

6. Describe the consequence to federal program or policy activities if the 

collection is not conducted or is conducted less frequently, as well as any 

technical or legal obstacles to reducing burden.

Section 207 of the LMRDA sets frequencies for filings of reports. If the information were 

collected less frequently, the obligations of the statute would not be met and the

Department would not have current information available to make the essential public 

disclosure and to conduct enforcement and oversight activities. 

7. Explain any special circumstances that would cause an information collection 

to be conducted in a manner:

• requiring respondents to report information to the agency more often 

than quarterly;

• requiring respondents to prepare a written response to a collection 

of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two 

copies of any document;

• requiring respondents to retain records, other than health, medical, 

government contract, grant-in-aid, or tax records for more than three 

years;

• in connection with a statistical survey, that is not designed to 

produce valid and reliable results that can be generalized to the 

universe of study;

• requiring the use of a statistical data classification that has not been 

reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by 

authority established in statute or regulation, that is not supported 

8
by disclosure and data security policies that are consistent with the 

pledge, or which unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other 

confidential information unless the agency can demonstrate that it 

has instituted procedures to protect the information's confidentiality 

to the extent permitted by law.

Records necessary to verify the required reports must be maintained for at least five 

years after the report is filed, which is the only special circumstance that requires this 

collection to be conducted in a manner inconsistent with the general guidelines in 5 

CFR 1320.6. The five-year retention period is established by the LMRDA (LMRDA Sec. 

206, 29 U.S.C. 436).

8. If applicable, provide a copy and identify the data and page number of 

publication in the Federal Register of the agency's notice, required by 5 CFR 

1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in response to 

that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their 

views on the availability of data, frequency of collection, the clarity of 

instructions and recordkeeping, disclosure, or reporting format (if any), and 

on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be 

obtained or those who must compile records should occur at least once every 

3 years -- even if the collection of information activity is the same as in prior 

periods. There may be circumstances that may preclude consultation in a 

specific situation. These circumstances should be explained.

The Department is publishing a 60-day notice seeking comment on the revision of this 

information collection. 

9. Explain any decision to provide any payment or gift to respondents, other than 

re-numeration of contractors or grantees.

The Department does not provide any payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the 

basis for the assurance in statute, regulation, or agency policy. (Note: If the 

submission will serve as Joint ICR and Privacy Impact Assessment per OMB 

Memorandum 03-22, Section II.D, the relevant justification shall be included 

as part of the agency’s response to this Item)

9
The contents of the reports filed pursuant to the LMRDA reporting requirements are, by 

law, public information. Therefore, no assurances of confidentiality are provided. 

11. Provide additional justification for any questions of a sensitive nature, such 

as sexual behavior and attitudes, religious beliefs, and other matters that are 

commonly considered private. This justification should include the reasons 

why the agency considers the questions necessary, the specific uses to be 

made of the information, the explanation to be given to persons from whom 

the information is requested, and any steps to be taken to obtain their 

consent.

No sensitive information is collected on the forms.

12. Provide estimates of the hour burden of the collection of information. The 

statement should:

• Indicate the number of respondents, frequency of response, annual 

hour burden, and an explanation of how the burden was estimated. 

Unless directed to do so, agencies should not conduct special 

surveys to obtain information on which to base hour burden 

estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is 

expected to vary widely because of differences in activity, size, or 

complexity, show the range of estimated hour burden, and explain 

the reasons for the variance. Generally, estimates should not 

include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide 

separate hour burden estimates for each form.

• Provide estimates of annualized cost to respondents for the hour 

burdens for collections of information, identifying and using 

appropriate wage rate categories. The cost of contracting out or 

paying outside parties for information collection activities should not 

be included here. Instead, this cost should be included in Item 14.

Table 1 details the annualized reporting and recordkeeping burden for all LMRDA public 

disclosure forms, and Table 2 details the annualized corresponding respondent cost 

estimates for such forms. The estimated number of reports in Table 1 reflects filing 

figures based on the average number of reports received from fiscal years 2008-2012.

In previous ICRs, the Department based its estimates on data from the previous fiscal 

year, but it now considers a five-year average the better approach, as it takes into 

account yearly fluctuation in data. The use of a five-year average increased the number 

of Form LM-2 responses and resulted in an increase in the total burden hours for the 

Form LM-2 and annualized burden hours for all forms. However, the burden hours per 

form are unchanged from prior estimates, as provided in the forms’ accompanying 

10
instructions, with the exception of Forms LM-2, LM-3, and LM-4. The Department has 

reduced the reporting burden for each of these forms as the result of its release of EFS.

In October 2010, OLMS successfully launched its second-generation electronic filing 

program, the Electronic Forms System (EFS), which does not rely on third-party 

software or require the purchase of digital signatures; instead, EFS is a secure, webbased system that uses electronic signatures which the filing organization’s two 

principle officers register for, along with the union obtaining a personal identification 

number (PIN) each year. EFS not only represents a significant cost savings, but a time 

savings as well.

The estimates provided in the below tables are identical to those of the Department’s 

most recent extension request for OMB #1245-0003. Although the Department is now 

amending the Form LM-3 and LM-4 instructions to require electronic filing via EFS, as 

well as amend the hardship exemption process for Form LM-2 filers, the Department 

made EFS available to Form LM-3 and LM-4 filers in 2011, anticipating that virtually all 

filers would take advantage of it. As a result, for its last three-year ICR renewal, in 

August 2013, the Department already estimated the cost savings associated with such 

electronic filing. Although the Department anticipated that all Form LM-3 and LM-4 filers 

would utilize EFS, not just the 40% of Form LM-3 filers and 37% of Form LM-4 filers that 

currently take advantage of the system, this amended ICR would mandate such filing, 

thus enabling all such filers to actualize the previously estimated burden reductions. 

Further, the Department does not estimate any burden change for Form LM-2 filers, as 

no filers have utilized the hardship exemption process in recent years. 

TABLE 1

ANNUALIZED REPORTING AND RECORDKEEPING BURDEN

Form Responses

Hours Per 

Response for 

Reporting

Reporting 

Burden H ours

Hours per 

Response for 

Recordkeeping

Recordkeeping 

Burden Hours Total Hours

LM-1 213 0.83 176.8 0.09 19.2 196.0

LM-2 6,073 140.20 851,434.5 390.00 2,368,470.0 3,219,904.5

LM-2 

Subsidiary 

Reporting* 577 18.00 10,386.0 69.71 40,222.7 50,608.7

LM-3 12,039 38.74 466,390.9 64.00 770,496 1,236,886.9

LM-4 7,387 7.18 53,038.7 2.00 14,774 67,812.7

LM-10 957 2.03 1,942.7 0.42 401.9 2,344.6

LM-15 310 1.50 465.0 0.33 102.3 567.3

LM-15A 33 0.33 10.9 0.03 1.0 11.9

LM-16 79 0.33 26.1 0.02 1.6 27.7

LM-20 387 1.38 534.1 0.25 96.8 630.9

LM-21 72 0.50 36 0.08 5.8 41.8

LM-30 1,474 1.67 2,461.6 0.33 486.4 2,948.0

S-1 75 0.50 37.5 0.08 6.0 43.5

SARF** 1,825 0.17 310.3 0.03 54,8 365.1

Total 31,501 -- 1,387,251.1 -- 3,195,138.5 4,582,389.6

11
Annualized

Note: Some numbers may not add due to rounding.

* The burden described here is for those Form LM-2 filers that also have subsidiary organizations. The 

burden for Form LM-3 subsidiary reporting is included in the Form LM-3 burden numbers.

** Simplified Annual Report Format

Table 2 shows estimates of the annualized cost to respondents for the hour burdens for 

the information collection. Source information for non-labor organization salaries is from 

the Occupational Employment and Wages Survey, 2012 survey, Tables 1 and 6, from 

the Bureau of Labor Statistics (BLS), Occupational Employment Statistics (OES)

Program. Source information for labor organization salaries is taken directly from 

annual reports filed with the Department and retrievable through e.LORS. Further, the 

Department determined the total compensation (salary plus fringe benefits) for each 

position by increasing each of the hourly wage rates by 42%, which is the percentage 

total of the average hourly benefits compensation figure ($8.57 in December 2012) over 

the average hourly wage figure ($20.32 in December 2012). See Employer Costs for 

Employee Compensation Summary, from the BLS at 

http://www.bls.gov/news.release/archives/ecec_03122013.pdf. The “responses” in 

Table 2 reflect totals described in Table 1. 

TABLE 2

ANNUALIZED RESPONDENT COST ESTIMATES 

Form Responses

Burden

Hours

Monetized 

Burden Hour 

Cost

LM-1 213 196 $6,640

LM-2 6,073 3,219,905 $150,433,962

LM-2 Subsidiary 

Reporting* 577 50,609 $1,428,166

LM-3 12,039 1,236,887 $42,907,610

LM-4 7,387 67,813 $2,298,183

LM-10 957 2,345 $212,564

LM-15 310 567 $33,827

LM-15A 33 12 $840

LM-16 79 28 $1,959

LM-20 387 631 $57,189

LM-21 72 42 $3,775

LM-30 1,474 2,948 135,926

S-1 75 44 $2,194

SARF** 1,825 365 $9,498

Annualized 31,501 4,582,392 $197,532,333

Note: Some numbers may not add due to rounding.

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* The burden described here is for those Form LM-2 filers that also have 

subsidiary organizations. The burden for Form LM-3 subsidiary reporting 

is included in the Form LM-3 burden numbers.

** Simplified Annual Report Format

13. Provide an estimate of the total annual cost burden to respondents or 

record-keepers resulting from the collection of information. (Do not 

include the cost of any hour burden shown in Items A.12 and A.14).

• The cost estimate should be split into two components: (a) a total 

capital and start-up cost component (annualized over its expected 

useful life); and (b) a total operation and maintenance and purchase 

of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or 

providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology 

acquisition, expected useful life of capital equipment, the discount 

rate(s), and the time period over which costs will be incurred. 

Capital and start-up costs include, among other items, preparations 

for collecting information such as purchasing computers and 

software; monitoring, sampling, drilling and testing equipment; and 

record storage facilities.

• If cost estimates are expected to vary widely, agencies should 

present ranges of cost burdens and explain the reasons for the 

variance. The cost of purchasing or contracting out information 

collection services should be a part of this cost burden estimate. In 

developing cost burden estimates, agencies may consult with a 

sample of respondents (fewer than 10), utilize the 60-day pre-OMB 

submission public comment process and use existing economic or 

regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or 

services, or portions thereof, made: (1) prior to October 1, 1995, (2) 

to achieve regulatory compliance with requirements not associated 

with the information collection, (3) for reasons other than to provide 

information or keep records for the government, or (4) as part of 

customary and usual business or private practices.

There are no operation and maintenance costs to respondents or recordkeepers 

resulting from the collection of information beyond the cost of the burden hours 

addressed in Item 12. Any capital investments including computers and software that 

are usual and customary expenses incurred by persons in the normal course of their 

business are excluded from the regulatory definition of burden as capital investments.

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14. Provide estimates of annualized cost to the Federal Government. Also, 

provide a description of the method used to estimate cost, which should 

include quantification of hours, operational expenses (such as equipment, 

overhead, printing, and support staff), and any other expense that would 

not have been incurred without this collection of information. Agencies 

also may aggregate cost estimates from Items A.12, A.13, and A.14 in a 

single table.

Table 8 provides a summary of federal costs associated with the information collections 

included in OMB # 1245-0003. Federal estimated costs include costs for contractors 

and operational expenses such as equipment, overhead, and printing as well as 

salaries and benefits for the OLMS staff in the National Office and field offices who are 

involved with reporting and disclosure activities. These estimates include time devoted 

to: (a) receipt and processing of reports; (b) disclosing reports to the public; (c) 

obtaining delinquent reports; (d) reviewing reports, (e) obtaining amended reports if 

reports are determined to be deficient; and (f) providing compliance assistance training 

on recordkeeping and reporting requirements. 

The OLMS national and field staff costs were derived from the GS scale. OLMS derived 

the other costs, associated with contractors, office space, and overhead and supplies, 

from its operating budget.

TABLE 3

ANNUALIZED FEDERAL COST ESTIMATES

National Office $1,825,935

Field Offices $3,279,173

Total $5,105,108

15. Explain the reasons for any program changes or adjustments.

There are no changes from the previous ICR extension request. 

16. For collections of information whose results will be published, outline 

plans for tabulation, and publication. Address any complex analytical 

techniques that will be used. Provide the time schedule for the entire 

project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

OLMS publishes the information collected pursuant to the LMRDA as reported. The 

submitted reports are made public via the OLMS website or upon request. While the 

public may download data from the published reports, OLMS does not post analyses of 

the data on its website. 

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17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be 

inappropriate.

The Department is not seeking an exemption from the display of the expiration date of 

the OMB approval of the information collection.

18. Explain each exception to the certification statement in ROCIS.

The Department is not requesting any exceptions to the certification statement required 

by the Paperwork Reduction Act. The Department is able to certify compliance with all 

provisions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods.

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