January 2009

Introduction 

Ensuring financial integrity and accountability and safeguarding union democracy for 

America’s union members is the mission of the Department of Labor’s Office of LaborManagement Standards (OLMS). In 1959, Congress enacted the Labor-Management Reporting 

and Disclosure Act (LMRDA) to combat union-related corruption, and OLMS continues today 

to pursue this important goal through criminal and civil enforcement of the LMRDA. 

The LMRDA establishes a bill of rights for union members; reporting and disclosure 

requirements for unions, union officers, union employees, employers, and others; rules for 

establishing and maintaining trusteeships; standards for the election of union officers; and 

safeguards for protecting union funds and assets. OLMS also administers Executive Order 

13201, which requires Federal contractors to notify employees of their rights concerning 

payment of union dues or fees. 

OLMS is the front line agency responsible for enforcing the LMRDA through its criminal 

investigations of embezzlement, deprivation of rights by violence, extortionate picketing, willful 

failure to file reports, filing false reports, and fraud related to union elections. Civil 

investigations include violations of the LMRDA in union election procedures, financial 

disclosure requirements, and trusteeship standards. 

OLMS also performs audits of union finances, administers a comprehensive compliance 

assistance program, and offers information and technical support to union officers and 

members to further the goals of financial integrity, union democracy, and transparency. 

OLMS at times conducts joint investigations with other Labor Department agencies, including 

the Employee Benefits Security Administration and the Office of Inspector General, as well as 

other law enforcement agencies including the Federal Bureau of Investigation. 

Summary Statistics 

Safeguarding Union Assets 

As part of its effort to protect and safeguard union funds and assets, OLMS investigates 

possible embezzlement from unions and other violations of criminal laws. Since 2001, 

restitution of $91,524,704 has been paid or ordered to be paid to defrauded unions and other 

parties. OLMS also conducts audits of local, intermediate and, international unions to ensure 

and promote their compliance with the LMRDA. 

2008 Annual Report 

Office of Labor-Management Standards

Employment Standards Administration 

U.S. Department of Labor 

Don Todd, Deputy Assistant Secretary
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OLMS Enforcement Statistics – Financial Integrity FY 2008 Change from 

FY 2001 

Criminal Cases Processed 391 +5.4% 

Indictments 131 + 32.0% 

Convictions 103 +1% 

Compliance Audits Conducted – Local + Intermediate Unions (CAP) 791 +232% 

Compliance Audits Conducted – International Unions (I-CAP) 7 +600% 

International Compliance Audits – Follow-up Audits 3 +300%

Financial Reporting and Recordkeeping 

OLMS offers compliance assistance sessions for union members and officials on the financial 

reporting and recordkeeping obligations under the LMRDA. OLMS also continued to provide 

extensive compliance assistance in the use of electronic filing software and the reporting 

requirements of the Form LM-2, the annual financial report for the nation’s largest unions. 

OLMS Enforcement Statistics – Reporting and Disclosure FY 2008 

Delinquent Reports Cases Processed 2016 

Deficient Reports Cases Processed 799 

Union Democracy 

When a union member files a timely complaint protesting a regularly scheduled election of 

union officers, OLMS initiates an investigation. If the investigation determines that the union 

violated the requirements of the LMRDA, the union may agree to allow OLMS to supervise a 

new election. If the union refuses to voluntarily agree to remedy the violation, OLMS may take 

legal action seeking a new election supervised by OLMS. 

The agency also conducts investigations to determine the validity of the imposition or 

continuation of trusteeships imposed by national unions on subordinate bodies. Trusteeship 

investigations are conducted upon receipt of a complaint from a member or subordinate body. 

OLMS Enforcement Statistics – Union Democracy FY 2008 

Election Investigations Conducted 131 

Lawsuits Filed 8 

Voluntary Compliance Agreements Obtained 28 

Supervised Elections 35 

Trusteeship Investigations 12 

Program Activities 

Criminal Enforcement

Union officers, employees, and representatives have a duty to manage the funds and property 

of the union solely for the benefit of the union in accordance with its constitution and bylaws. 

A union officer or employee who embezzles or misappropriates union funds or assets commits 

a federal crime punishable by a fine and/or imprisonment. OLMS is responsible for 

investigating these crimes. Its vigorous criminal enforcement program has resulted in 972 

indictments and 904 convictions since the beginning of FY 2001. Following are some of the 

most significant cases from FY 2008. 
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Guilty Plea for Forgery and Theft of 

$454,406 from Transit Union 

An investigation by OLMS led to the 

indictment and conviction of Thomas 

Wallace, former Financial SecretaryTreasurer of the Amalgamated Transit 

Union (ATU) Division (Div) 757 in 

Portland, Oregon. The investigation 

established that Wallace wrote a series of 

unauthorized union checks to himself 

totaling $454,406 over a six-year period. He 

pled guilty to one count of uttering a forged 

security (18 USC 513) on May 20, 2008. As a 

part of the plea agreement Wallace 

acknowledged responsibility for the entire 

$454,406 loss and agreed to pay full 

restitution. 

IBEW Local 163 Suffers More than 

$256,000 Loss 

Joseph Capece, former business manager of 

the International Brotherhood of Electrical 

Workers (IBEW) AFL-CIO Local 163 in 

Wilkes-Barre, Pennsylvania. used the 

union’s debit and credit cards to make cash 

withdrawals and pay personal charges at 

the union’s expense. Capece was sentenced 

to six months imprisonment on March 18, 

2008. Once released from incarceration, 

Capece must serve two years probation 

with six months of home confinement. 

Capece was fined $4,000 and ordered to pay 

a special assessment fee of $100. Capece 

repaid Local 163 approximately $250,000 

prior to sentencing. 

Asbestos Workers Business Agent 

Embezzles $829,762 from Union and 

Training Funds 

John Dabronzo, former Business Agent and 

Joint Apprenticeship and Training 

Committee (JATC) Administrator of 

Asbestos Workers Local 89, Trenton, New 

Jersey, pled guilty to an information 

charging him with one count of 

embezzlement of union funds in violation 

of 29 U.S.C. 501(c) in the amount of $433,308 

and one count of embezzlement of JATC 

funds in violation of 18 U.S.C. 664 in the 

amount of $396,455. During the period May 

2005 through April 2007 Dabronzo 

absconded with 300 employer remittance 

checks from the union office totaling 

$433,308. The employer remittance checks 

should have been deposited into the 

Asbestos Workers Local 89 Distribution 

Fund. However, from May 2005 through 

April 2007, Dabronzo deposited these 

checks into the Asbestos Workers Local 89 

JATC Fund checking account and received 

the proceeds of 276 checks totaling $396,455 

that were withdrawn from the JATC Fund. 

Dabronzo wrote the checks out to himself 

and cash. This investigation was worked 

jointly with the Department of Labor’s 

Office of the Inspector General and the 

Employee Benefits Security Administration. 

Filing a False LM Report Leads to AFGE 

Conviction 

An investigation by OLMS led to the 

indictment and conviction of Karimah 

Bailey, former Treasurer of the American 

Federation of Government Employees 

(AFGE) Local 3197 in Seattle, Washington. 

The investigation established that Bailey 

embezzled union funds totaling $98,802 

over a two-year period. She pled guilty to 

making a false statement and representation 

of a material fact, knowing it to be false, on 

the local’s annual financial report (18 USC 

1001). As a part of the plea agreement 

Bailey acknowledged responsibility for the 

entire $98,802 loss and agreed to pay full 

restitution. 

AFSCME Employee Pleads Guilty and 

Sentenced for Embezzlement 

Zona Albritton, former Manager of General 

Services for the American Federation of 

State, County and Municipal Employees 

(AFSCME), pled guilty to one count of 
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embezzling $75,446 from the union between 

December 2003 and April 2004. Albritton 

was responsible for hiring contractors to 

paint and install carpeting in AFSCME’s 

headquarters building in Washington, DC. 

Albritton hired contractors to complete the 

work, then submitted vouchers so the 

contractors were paid by AFSCME. In 

addition to these legitimate vouchers, 

Albritton submitted vouchers to AFSCME 

for the same work to be paid to a shell 

company she created and used for personal 

purposes. On June 26, 2008, Albritton was 

sentenced to one year and one day in 

prison, three years probation and ordered to 

make full restitution. 

Boilermakers Secretary/Treasurer 

Indicted 

An investigation by OLMS led to the 

indictment of Joseph Michael Johnson, 

former Secretary-Treasurer of Boilermakers 

Local Lodge 687 in Charleston, South 

Carolina. The investigation established that 

Johnson embezzled a total of $102,519 from 

the local lodge between July 2004 and July 

2006. Johnson employed several schemes in 

converting lodge funds to his personal use. 

First, he wrote 118 checks to seven lodge 

members who served as apprenticeship and 

training instructors for work that was never 

performed. Johnson signed the checks and 

used a signature stamp as a second 

signature; he then endorsed and deposited 

the checks into his own personal account. 

Second, Johnson took cash contributions 

from the union’s Good Cheer Fund --

monies from that fund were supposed to be 

used for sick or distressed members and 

their families. Third, Johnson wrote an 

additional 20 checks to various vendors for 

personal purchases and caused the local to 

incur overdraft and non-sufficient fund 

charges. Johnson was indicted on one count 

of embezzling $102,519 on September 10, 

2008. 

Sindicato Obreros Unidos del Sur 

President Indicted 

An investigation by OLMS and the FBI led 

to the indictment and arrest of Jose L. 

Caraballo-Figueroa, President of Sindicato 

Obreros Unidos del Sur in Salinas, Puerto 

Rico. Caraballo was indicted on two counts 

of violating 29 USC 501(c). The first count 

was for embezzlement of union funds in 

excess of $400,000 during the period 

December 2000 through December 2007. 

The embezzlement was carried out under 

the guise of medical reimbursements, 

payments for services rendered, and 

payments for meals and car expenses. The 

second count charged Caraballo with 

unlawfully and willfully converting $49,500 

to his own use by issuing a counter check 

from the union’s account. Caraballo was 

indicted on August 13, 2008.

OLMS Investigation Discloses False 

Statement on Union’s Annual Report 

Brad Harper, former treasurer of AFGE 

Local 1629 in Battle Creek, Michigan, was 

indicted, convicted, and sentenced for 

making materially false statements on one 

of the local’s annual financial reports filed 

with the Secretary of Labor. The OLMS 

investigation established that Harper made 

unauthorized ATM cash withdrawals and 

unauthorized personal charges on the 

union’s credit card totaling $75,069 over a 

five-year period. Harper pled guilty on 

August 9, 2007 and was sentenced on 

January 29, 2008. At sentencing, he received 

a 14-month prison sentence followed by 3 

years of supervised release. He was also 

ordered to make full restitution to the 

union. 

Teamster Local 19 Substitution Scheme 

Leads to Conviction and Sentencing 

Heather Lott, the former bookkeeper of the 

International Brotherhood of Teamsters 

Local 19 in Houston, Texas, embezzled 
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$140,952 by writing 96 unauthorized checks 

to herself and concealing her actions by 

entering a fictitious payee in the union’s 

financial database. When the cancelled 

checks were sent to the local union as part of 

the monthly bank statement, Lott discarded 

the checks to prevent detection. As a result 

of her guilty plea to embezzlement of 

$140,000, Lott was sentenced to 18 months in 

federal prison, ordered to pay restitution of 

$140,952 and serve three years of supervised 

release upon completion of her prison term. 

This conviction was the result of a joint 

investigation with the Department of Labor’s 

Office of Inspector General. 

Former Transit Union President and Wife 

Arrested 

Bobby Williams, former president of Transit 

Union, AFL-CIO Local Division 1635, and 

Janice Williams, his wife, were arrested on 

June 19, 2008, after being indicted on twenty 

counts of forgery by a grand jury in Dallas, 

Texas. The couple, the indictment states, 

obtained $23,230 in union funds by forging 

the signature of the union’s former secretarytreasurer on union checks over a period of 

fourteen months. The couple posted a $1,500 

bond and are currently awaiting trial. 

Indictment and Guilty Plea for Theft of 

$170,000 from NALC Local 

Following an OLMS investigation and a 2007 

indictment, Graham Paul Vance, former 

president of National Association of Letter 

Carriers Local 1280 and an officer for 10 

years, plead guilty to embezzling more than 

$170,000. Vane used 12 union credit cards 

for non-union-related charges and used 

union funds to pay his personal credit card 

charges. Vane was sentenced to 15 months 

in prison for embezzlement and making false 

statements to the Department of Labor. He 

was ordered to pay $150,000 restitution and 

a $500 special assessment. Vane will be 

placed on supervised release for three years 

following his incarceration. 

Steelworkers Union to Receive Full 

Restitution of Stolen Funds 

An OLMS criminal investigation established 

that from February 26, 2003 to December 16, 

2004, former Office Secretary/Financial 

Secretary Deborah Anthony of Steelworkers 

Local 1196 in Brackenridge, Pennsylvania. 

converted union funds totaling $34,134.47 to 

her own use. In addition to writing 

unauthorized checks to herself, Anthony 

wrote unauthorized checks to third party 

vendors with names similar to or the same as 

legitimate local union vendors to pay her 

personal bills. On March 14, 2008, Anthony 

pled guilty to one count of embezzling union 

funds totaling $1,245.45. Anthony was 

sentenced on July 22, 2008 to five years 

probation, ordered to serve one year home 

detention and pay full restitution. 

Embezzlement of Over $145,000 Found in 

Graphic Communications Local 

Following an investigation by OLMS and the 

Department of Labor Office of Inspector 

General, Betty Illig, former secretarytreasurer for Graphic Communications 

Worker Local 638-S and the Tri-State District 

Joint Council, located in East Liverpool, Ohio 

plead guilty to embezzling $145, 675 in 

union funds from the two labor 

organizations and submitting false Form 

LM-3 Reports. The investigation disclosed 

that Illig paid herself salary, rent payments 

for a home office, expenses for union 

business allegedly conducted in her home, 

and lost time expenses that were not 

authorized by the union. In order to convert 

this money to her own use, Illig used the 

local president's signature stamp to sign the 

improper checks. Illig was sentenced to one 

year home confinement with electronic 

monitoring followed by four years 

probation, 200 hours of community service, 

and a $200 special assessment. She was also 

ordered to make full restitution to the union. 
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Financial Reporting and Recordkeeping

Division of International Union Audits 

The Division of International Union Audits 

(DIUA), established by OLMS in 2004, has 

completed its fourth full year conducting 

the International Compliance Audit 

Program (I-CAP). 

During FY 2008, unions completed their 

third fiscal year under the Department's 

revised recordkeeping and reporting 

requirements, submitting their annual 

financial disclosure forms (Form LM-2s) 

using electronic filing software. Of the 

seven audits and three follow-up audits 

DIUA and field offices conducted in FY 

2008, six were of unions that had submitted 

their Form LM-2 electronically. One union 

was not required to file electronically since 

it files Form LM-3. DIUA also began work 

on two additional audits and two follow-up 

audits that will be completed in FY 2009. 

DIUA continues to focus predominately on 

international unions with no prior audit 

history and plans to complete seven audits 

and seven follow-up audits in FY 2009. 

The audit findings are provided to the 

unions in closing letters, which are later 

posted on the OLMS Web site, 

www.olms.dol.gov . For serious deficiencies 

and violations that have not been corrected 

by the union at the time of the exit 

interview, DIUA conducts follow-up audits 

to review LMRDA compliance, discuss the 

corrective actions the union has taken to 

resolve deficiencies, and continue 

cooperative efforts to assist the union in 

coming into compliance. 

During the FY 2008 audits and follow-up 

audits, DIUA staff identified a total of 146 

violations of the LMRDA and instances of 

inadequate internal controls: 

• 64 involved reporting deficiencies. 

• 31 concerned inadequate record-keeping 

violations. 

• 34 related to inadequate internal controls. 

• 7 included fiduciary responsibility, 

bonding, and office-holding prohibitions. 

Compliance Assistance 

For the past year, OLMS has undertaken 

a comprehensive compliance assistance 

program: 

• OLMS continued its program of 

structured, nationwide compliance 

assistance seminars. The goal of this 

program is to provide an 

opportunity each year for the officers 

of every labor organization to attend 

a compliance assistance seminar. 

The content of each year’s 

compliance assistance seminar is 

similar throughout the country so 

that every officer in attendance is 

exposed to the same material. OLMS 

conducted 112 seminars in FY 2008. 

• OLMS posted extensive Frequently 

Asked Questions (FAQs) on the 

revised Form LM-30 on its web site. 

OLMS presented a revised Form 

LM-30 training session in the DOL 

auditorium on October 9, 2008. 

• OLMS continues to promote and use 

an electronic mailing list system to 

send email messages to unions, 

accountants, union members, and 

other interested individuals. The 

electronic mailing list has 2,445 

subscribers and OLMS sent 16 such 

messages FY 2008. 
7

• OLMS created a Spanish language 

page on its web site that describes 

the agency and its mission and links 

to Spanish language compliance 

assistance materials. 

• OLMS updated an on-line guide to 

help labor organizations apply 

digital signatures to their electronic 

annual financial disclosure forms 

and to troubleshoot common digital 

signature issues. 

• OLMS introduced a toll-free number 

for its Electronic Filing Help Desk. 

• OLMS posted a fact sheet on 

Observer Rights and Responsibilities 

in Elections of Union Officers on its 

web site. 

• OLMS posted public and private 

sector collective bargaining 

agreements on its web site. 

Union Advisory Services Program 

OLMS continued a program of union 

advisory services initiated in FY 2007 to 

provide enhanced advisory support and 

compliance assistance to labor 

organizations. A primary function of the 

program is to review union constitutions 

and bylaws to determine if any provisions 

may conflict, or be applied to conflict, with 

the law and to advise unions of any changes 

needed to bring those provisions into 

compliance with the law. In FY 2008 OLMS 

completed 82 reviews and mailed 56 

constitution review letters to unions.

Under the union advisory services program, 

OLMS also reviewed union compliance 

with Form LM-1, Labor Organization 

Information Report requirements. If a 

union’s constitution and bylaws do not fully 

explain the union’s policy and procedures 

on specified matters, this information must 

be detailed on a Form LM-1 report. Matters 

that must be reported include how 

assessments are imposed on members, 

procedure for authorizing disbursement of 

union funds, how contracts are ratified, and 

how strikes are authorized. In FY 2008, the 

agency prepared 82 letters to unions 

seeking new or amended Form LM-1 

reports. 
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Union Democracy

The LMRDA establishes democratic standards for conducting union officer elections, such as 

the frequency and method of election, the right of members in good standing to be candidates, 

rights of candidates, and voting rights of members. OLMS will conduct an investigation upon 

receiving a timely filed complaint from a union member alleging that the LMRDA has been 

violated. If the investigation determines that the election provisions have been violated, OLMS 

may negotiate a voluntary agreement to have the union rerun the election under OLMS 

supervision or OLMS may take legal action seeking a new election. When warranted, OLMS 

investigates criminal violations associated with elections including ballot fraud, false 

statements, and deprivation of rights under the Act by violence. Following are highlights of 

some of the most significant OLMS election cases during FY 2008. 

OLMS Successful in Lawsuits filed on 

Consecutive Elections Conducted by 

ILWA Local 10 

Longshore and Warehouse Workers Union 

(ILWU) Local 10 represents about 1,000 

members who work as longshoremen in 

ports around the San Francisco Bay Area 

and holds annual elections of officers. 

On October 24, 2007, OLMS prevailed in a 

lawsuit filed against ILWU Local 10 over 

the union’s 2005 election of officers. OLMS 

filed the lawsuit after it was determined 

that ILWU Local 10 denied a candidate the 

opportunity to run for office when the local 

union required candidates to “clear their 

books” before nominations even though 

that requirement did not appear in the 

union’s constitution, bylaws, or rules. 

Subsequently, the union held its 2006 

election of union officers, which OLMS 

determined suffered from a similar 

violation of the law. This time the union 

applied a good-standing requirement as if it 

required continuous good standing even 

though the constitutional language was not 

clear as to what was required. A second 

lawsuit was filed. On December 7, 2007, the 

union and OLMS settled the lawsuit over 

the 2006 election. 

Local 10 attempted to prevent OLMS from 

supervising the 2007 election, which was 

already underway at the time the court 

issued its ruling. However, the court 

ordered that the election could proceed only 

under OLMS supervision. The remedial 

election supervised by OLMS resolved both 

lawsuits and included the positions of vicepresident, business agents, trustees, 

executive board members, and delegates. 

The election was completed in February 

2008. 

Election of 32,000 Member Local in Los 

Angeles Supervised by OLMS 

American Federation of Television and 

Radio Artists, Los Angeles Local (AFTRA 

LA), located in Los Angeles, California, is a 

labor union representing performers, 

journalists and other artists, with over 

32,000 members. AFTRA LA members 

perform on public and cable television, on 

radio, and in sound recording studios. 

OLMS determined that the union failed to 

properly tally the ballots in its May 22, 2007 

challenged election and did not provide 

sufficient notice of the election to 354 

members. On December 14, 2007, OLMS 

and AFTRA LA entered into a voluntary 

settlement. The settlement agreement 

provided that the union would conduct a 

new election, under OLMS supervision, for 

nine positions on the Los Angeles Board of 
9

Directors – Actor category, and thirteen 

positions on the AFTRA National Board of 

Directors – Los Angeles Local 

Representatives. The supervised election 

was completed April 15, 2008. 

OLMS Supervised Election of District 14 

National Vice President for American 

Federation of Government Employees 

OLMS filed suit in U.S. District Court for 

the District of Columbia seeking to overturn 

the 2005 election conducted by the 

American Federation of Government 

Employees (AFGE) for the office of District 

14 Vice President. On March 1, 2007, to 

settle the lawsuit, OLMS and AFGE entered 

into a court-approved settlement whereby 

OLMS would first either certify or supervise 

elections of delegates in 68 local unions and 

then supervise the election of the District 14 

Vice President by those delegates at the 

District 14 Caucus on May 17, 2008. 

OLMS supervised all aspects of these 

elections, including nominations, mailing of 

ballots or onsite voting, and the ballot tally. 

AFGE District 14 encompasses 68 local 

unions that represent approximately 14,800 

members employed by the U.S. 

Government and the District of Columbia 

Government in the Washington, DC area. 

American Postal Workers Union Local 

732 reached a Settlement Agreement 

with OLMS 

OLMS filed a lawsuit against American 

Postal Workers Union, AFL-CIO Local 732 

in Dallas, Texas, on January 4, 2008, when 

an OLMS investigation revealed that the 

candidates on the incumbent slate used a 

different and more accurate mailing list to 

mail their campaign literature than the list 

provided to their opponents. On April 15, 

2008, the lawsuit resulted in a courtapproved settlement agreement for a 

remedial election under OLMS supervision. 

The agreement included a new election and 

nominations, as necessary, for the positions 

of president, executive vice president, 

sergeant-at-arms, one trustee, directorhuman resources, clerk craft assistant 

director, clerk craft business agent #4, clerk 

craft delegates (14 of the 29 positions), 

maintenance craft business agent #2, 

maintenance craft delegates (4 of the 6 

positions), and motor vehicle service craft 

delegates (2 of the 3 positions). The union 

represents over 3,800 members employed 

by the United States Postal Service in 

Dallas, Texas. The supervised election was 

completed on July 19, 2008. 

OLMS Supervised SEIU Local 1107 

November 2008 Election 

OLMS negotiated a voluntary settlement 

agreement with the Service Employees 

International Union (SEIU) Local 1107 in 

Las Vegas, Nevada after investigating four 

complaints challenging the union’s election 

of officers conducted on September 4 and 5, 

2007. The investigation disclosed that some 

candidates were not given equal access to 

union steward lists that some candidates 

used to make campaign phone calls; 

employer resources were used to collect 

contributions donated to a slate’s campaign 

fund; and employer funds were used in 

preparing and mailing campaign literature. 

Local 1107 agreed to conduct a new election 

under OLMS supervision for the positions 

of president, executive vice president, 

secretary, three trustee positions, vice 

president for the City of Las Vegas Housing 

Authority, chief steward for the City of Las 

Vegas Housing Authority, nursing chief 

steward for St. Rose San Martin, and vice 

president for Sunrise Hospital. The 

remedial supervised election of the 10,000- 

member local union was completed in 

November, 2008. 
10 

Regulatory Activities

Changes to the Form LM-2 and Form LM-3 

On December 5, 2008, OLMS submitted to 

the Office of Management and Budget, for 

formal review, a final rule revising the Form 

LM-2. The Form LM-2 is used by the largest 

labor organizations to file their annual 

financial reports. The rule will provide 

additional information on Schedules 3 (sale 

of investments and fixed assets), 4 

(purchase of investments and fixed assets), 

11 (all officers and disbursements to 

officers) and 12 (disbursements to 

employees), add itemization schedules to 

specified categories of receipts, and 

establish a procedure by which OLMS may 

revoke a union's privilege to file the 

simplified annual report, Form LM-3, where 

appropriate, after investigation, notice, and 

opportunity for a hearing. 

Form T-1 Trust Annual Report 

On October 2, 2008, OLMS published a Final 

Rule implementing the Form T-1, Trust 

Annual Report. The Form T-1 is an annual 

financial disclosure report filed by labor 

unions about certain “trusts” in which they 

are interested. These trusts include, for 

example, building and redevelopment 

corporations, educational institutes, credit 

unions, labor union and employer joint funds, 

and job targeting funds. 

Labor unions will use the Form T-1 to disclose 

financial information about the trust, such as 

assets, liabilities, receipts and disbursements. 

The Form T-1 final rule will take effect on 

January 1, 2009. The fiscal year of both the 

labor union and its trust must therefore begin 

on or after January 1, 2009 for a Form T-1 

report to be owed. The Form T-1 covers the 

trust’s most recently completed fiscal year, 

that is, the fiscal year ending on or before the 

closing date of the labor union’s fiscal year.