Introduction

From the founding of the United States through today, labor unions have performed an essential function 

in the American economy by providing a voice for workers in their workplace. They do this by 

negotiating and enforcing agreements with employers to promote employee safety, equitable policies, 

and fair pay. Labor unions advance the economic aspirations of their members, those in the middle class 

and those aspiring to reach the middle class. They raise wages and improve working conditions, and 

they do so with an even hand. They create equity among diverse communities by closing wage gaps that 

divide the nation by race, gender, and ethnicity. They were and remain in the forefront of the movement 

for social justice, promoting benefits for their members – the forty-hour week and overtime pay, 

retirement security and health insurance, to name just a few – long before these benefits were embodied 

in national and state law.

The mission of the Office of Labor-Management Standards (OLMS) has the effect of strengthening 

unions. OLMS is tasked with protecting unions and their members by administering the LaborManagement Reporting and Disclosure Act (LMRDA) and related laws. OLMS protects labor 

organizations and their membership by promoting financial integrity through its compliance audit and 

criminal enforcement programs. Furthermore, OLMS promotes transparency by reviewing union, 

employer, and persuader reports for accuracy and making them available to the public. Finally, OLMS 

conducts investigations of complaints filed by members concerning regularly scheduled union officer 

elections and trusteeships to protect the democratic process in the election of labor movement leaders by 

their membership. Unions are strong when they operate democratically, are free from corruption, and 

are transparent in their operations. OLMS is successful in its mission when strong, democratic, and 

transparent unions have the full confidence of workers, employers, and policy makers.

By taking regulatory and policy actions, discussing the benefits that labor unions offer, enforcing 

reporting of anti-union employer conduct, sponsoring far-reaching research projects, contextualizing 

labor union enforcement data with employer enforcement data, and modernizing its website, the OLMS 

mission inherently strengthens unions, enabling the labor movement to contribute to the hard work of 

creating greater equity and economic security. While this report for fiscal year 2021 (October 1, 2020 

through September 30, 2021), by its very nature, highlights the instances when unions and their officers 

or employees fail to live up to the standards set for them, these are the exceptions which prove the rule: 

the vast and overwhelming majority of unions and their officers and employees do their work exactly as 

the American people expect them to do. 

2021 Annual Report

Office of Labor-Management Standards

U.S. Department of Labor

Jeffrey R. Freund, Director 
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The Law

When the LMRDA was enacted in 1959, Congress reiterated what it had found in 1935 when it enacted 

the National Labor Relations Act, stating that “in the public interest, it continues to be the 

responsibility of the Federal Government to protect employees’ rights to organize, choose their own 

representatives, bargain collectively, and otherwise engage in concerted activities for their mutual aid 

or protection.” To help achieve that end, Congress declared that “it is essential that labor organizations, 

employers and their officials adhere to the highest standards of responsibility and ethical conduct in 

administering the affairs of their organizations, particularly as they affect labor-management relations.” 

The LMRDA primarily promotes union democracy and financial integrity in private sector labor 

unions through standards for union officer elections and union trusteeships and safeguards for union 

assets. Additionally, the LMRDA promotes transparency through reporting and disclosure 

requirements for labor unions and their officials, employers, labor relations consultants, and surety 

companies. OLMS continues today to protect union members and their right “to organize, choose their 

own representatives, bargain collectively, and otherwise engage in concerted activities for their mutual 

aid or protection” by pursuing this important mission through criminal and civil enforcement of the 

LMRDA.

The major provisions of the LMRDA are, by title:

• Title I: Bill of Rights for union members;

• Title II: Requirements for reporting and disclosure by labor unions, union officers and 

employees, employers, labor relations consultants and surety companies;

• Title III: Rules for establishing and maintaining trusteeships;

• Title IV: Standards for conducting fair elections of union officers; and 

• Title V: Safeguards for protecting union funds and assets.

Unions representing U.S. Postal Service employees became subject to the LMRDA with the passage of 

the Postal Reorganization Act of 1970.

OLMS also administers provisions of the Civil Service Reform Act of 1978 and the Foreign Service 

Act of 1980, which extend comparable protections to federal labor unions. In addition, OLMS 

administers the Department’s responsibilities under the Federal Transit Act by ensuring that fair and 

equitable arrangements protecting mass transit employees are in place before the release of federal 

transit grant funds.

OLMS is the front line agency responsible for safeguarding union assets, promoting democracy by 

enforcing the LMRDA through its criminal and civil investigations, and creating transparency about 

employer efforts to persuade workers on how to exercise their rights protected by federal labor laws. 

Criminal investigations include embezzlement, deprivation of rights by violence, extortionate 

picketing, willful failure to file reports, destruction of records, filing false reports, prohibition of 

convicted persons from holding union office or employment, and fraud related to union elections. 

Civil investigations include violations of the LMRDA involving union election procedures, financial 

disclosure requirements, and trusteeship standards. OLMS also conducts audits of union finances.
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Compliance assistance also plays a major role in OLMS enforcement strategy. OLMS has an active 

compliance assistance program to promote voluntary compliance with the LMRDA by informing union 

officers and employees as well as employers and employer-consultants of their responsibilities and 

informing members of their legal rights.

Summary

This report consists of seven sections, with related tables and charts.

• Section 1 presents key fiscal year (FY) 2021 criminal enforcement and performance results 

pursuant to LMRDA Title V (financial safeguards for labor organizations) together with 

noteworthy criminal enforcement actions. A complete listing of the calendar year (CY) 2021

criminal actions is located on the OLMS website along with those of prior calendar years. It 

bears noting in this Summary that of the more than 200,000 union officers and employees, fewer 

than 0.025% were convicted for having broken their trust with the members they represent.

OLMS’ 2021 experience is similar to its experience over the last 5 years.

• Section 2 presents key FY 2021 civil enforcement and performance results pursuant to LMRDA 

Title III (trusteeships) and Title IV (union officer elections) together with noteworthy union 

officer election case summaries for 2021. A listing of all 2021 voluntary agreements for OLMSsupervised union officer elections is located on the OLMS website along with those of prior 

calendar years. FY 2021 court actions for election investigations are located on the OLMS 

website along with those of prior calendar years. Final decision letters in election and trusteeship 

cases are located on the OLMS website in the FOIA reading room. As with OLMS’ criminal 

enforcement activities, it bears noting that of the more than 7,000 union officer elections estimated 

to have taken place in 2021, members filed viable complaints in only 78 elections and OLMS 

found a basis for proceeding in only 22 of those. And as regards trusteeships, reports were filed 

reflecting 47 subordinate bodies (local or intermediate unions) having been placed in trusteeship 

and OLMS had a basis for opening only 17 investigations predicated on complaints or other 

factors. These 2021 results for elections and trusteeships are also consistent with OLMS’ 

experience over the last 5 years.

• Section 3 presents reporting and disclosure data and related program activity pursuant to LMRDA 

Title II (reporting requirements). Section 3 also presents key 2021 reporting, enforcement and 

performance results. Reports are available for public disclosure on the OLMS Online Public 

Disclosure Room.

• Section 4 summarizes grant certification activity pursuant to the section 13(c) program, which 

ensures fair and equitable arrangements protecting mass transit employees, as required by the 

Federal Transit Act.

• Section 5 provides an overview of the OLMS regulatory initiatives in FY 2021. 

• Section 6 briefly describes compliance assistance activities conducted in FY 2021.

• Section 7 discusses OLMS outreach efforts undertaken in FY 2021.

OLMS Annual Reports for 2004–2020 are located on the OLMS website.
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Program Activities

1. Safeguarding Union Assets

As part of the effort to protect and safeguard the union funds and assets belonging to hard-working 

union members, OLMS investigates possible embezzlement from unions and other violations of 

criminal laws. 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. While the 

vast majority of union officers and employees do their work diligently and without incident, 

unfortunately criminal violations do sometimes occur and, when they do, the union is the victim. 

When a union officer or employee violates their position of trust by embezzling or misappropriating

union funds or assets, they commit a federal crime punishable by imprisonment or fine, or both. 

OLMS is responsible for investigating these crimes. 

Further, section 504 of the LMRDA prohibits individuals convicted of certain crimes from holding 

union office or employment or serving in other specified capacities. The bar continues for 13 years 

after conviction or after the end of imprisonment, whichever is later. OLMS is also responsible for 

investigating violations of section 504 in addition to other violations including embezzlements of 

union funds and the willful failure to file complete and accurate financial and other reports with 

OLMS or to maintain records. These investigations may result in criminal prosecutions.

OLMS monitors activities involving union funds to help safeguard such funds from criminal conduct. 

There are over 20,000 unions that file LM reports with OLMS and, among those unions, upwards of 

200,000 elected officers and employees. During the past five years OLMS has opened annually on

average around 217 criminal investigations. Those investigations have led to between 60 and 79 

criminal convictions annually over the last five years. While many of those convicted were union 

officers or employees, others were not. For example, out of the 48 criminal convictions reported for 

2021, four were convictions of employers, vendors or others whose criminal conduct affected union 

funds.

OLMS also conducts audits of labor unions both to detect embezzlements and promote compliance 

with the LMRDA. This effort extends to every level of labor organizations, from local unions to 

intermediate bodies, national and international unions. Compliance audit closing letters are located on 

the OLMS website. Because it is not feasible for OLMS to audit every union, OLMS developed a 

methodology to direct its auditing resources to unions whose metrics suggest the possibility that there 

may have been criminal activity, diverting resources from audits of organizations with less potential 

of criminal activity to other programs. The effectiveness of this methodology is measured by the 

percent of audits resulting in the opening of a “fallout” criminal case. A higher or lower than 

expected fallout rate measures only the “efficiency” of OLMS’ targeting strategies and says nothing 

(either positively or negatively) about the amount of criminal activity involving union funds.

In 2021, OLMS fell short of its performance goal in this area, achieving a fallout rate of 15.25 percent

with a target of 16.75 percent. Despite the disruption caused by the COVID-19 pandemic, travel 

restrictions, and diminished staff training, OLMS met its goal in planned criminal investigations with 

strong results in other financial integrity areas. 
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 OLMS Performance Goal – Financial Integrity FY 2021 Target FY 2021 Results

Percent of Audits Resulting in a Criminal Case 16.75% 15.25%

 OLMS Enforcement Statistics – Financial Integrity FY 2021 Plan FY 2021 Results

Criminal Investigations Completed 202 202

Indictments 80 56

Convictions 80 48

Compliance Audits Conducted 237 221

Below are summaries of notable cases resulting from OLMS investigations during FY 2021. 

Former Union Officer Sentenced to Home Confinement for Wire Fraud and Forged Securities

In October 2020, Rocky Gannon, former President of American Federation of Government Employees 

Local 2302, located in Fort Knox, Kentucky, was sentenced to 15 months of home confinement, four 

years of probation, and 250 hours of community service. He was also ordered to pay $116,353 in 

restitution and a $1,200 assessment. In June 2020, Gannon pleaded guilty to three counts of wire fraud 

and nine counts of forged securities. The OLMS investigation found that Gannon converted union funds 

by making electronic payments to the union credit card company for personal charges, forging checks, 

and creating false invoices. 

Former Union Employee Sentenced to Prison for Embezzlement

In October 2020, Rick E. Drain, former business manager for Laborers Local 1085, located in 

Parkersburg, West Virginia, was sentenced to one year and one day in prison and one year of supervised 

release. He was also ordered to pay $59,181 in restitution and a $100 special assessment. In July 2020, 

Drain pleaded guilty to one count of embezzling union funds. The OLMS investigation discovered that 

Drain diverted funds from initiation fees and direct dues, withheld cash from bank deposits, and 

received unauthorized union checks.

Former Union Officer Sentenced to Home Confinement Following $119,000 Embezzlement 

In November 2020, Angel Luis Garcia, former Financial Secretary of Amalgamated Transit Union Local 

1614, located in Dover, New Jersey, was sentenced to 12 months of home confinement with electronic 

monitoring and three years of supervised release. Garcia was ordered to pay $119,021 in restitution and 

a $100 special assessment. In June 2020, Garcia pleaded guilty to one count of embezzling union funds. 

The OLMS investigation disclosed that Garcia used union funds to pay for his personal telephone bills, 

home mortgage payments, personal loans, and to purchase personal goods at Home Depot, Amazon, and 

BestBuy. He also issued himself duplicate salary payments. 
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Five Former UAW Officials and Fiat Chrysler Sentenced for Union-Auto Industry Corruption

In 2021, the ongoing investigation of union and auto industry corruption involving the United Auto 

Workers International Union (UAW) in Detroit, Michigan, and the UAW Region 5 and Midwest 

Community Action Program (CAP) Council, both in St. Louis, Missouri, and Fiat Chrysler Automobiles 

US LLC resulted in six additional convictions in the United States District Court for the Eastern District 

of Michigan. The joint investigations conducted with the Department of Labor’s Office of Inspector 

General, the Federal Bureau of Investigation, and the Internal Revenue Service focused on criminal 

conspiracies in which UAW officials committed fraud and embezzlement, took bribes and kickbacks, 

and laundered money. 

Between November 2020 and July 2021, five more individuals were sentenced for crimes involving the 

UAW. Dennis Williams and Gary Jones, former UAW Presidents; Vance Pearson, former UAW 

Region 5 Director; and Edward “Nick” Robinson, former UAW Midwest CAP Council President, all 

were sentenced to prison following guilty pleas for conspiracy to embezzle union funds. Jones and 

Pearson also pleaded guilty to conspiracy to use a facility of interstate commerce to aid a racketeering 

enterprise, and Jones and Robinson pleaded guilty to conspiracy to defraud the United States. Joseph 

Ashton, former UAW Vice President in the General Motors (GM) Department and Director of the 

UAW-GM Center for Human Resources, was also sentenced to prison after he pleaded guilty to 

conspiracy to commit honest services wire fraud and one count of conspiracy to commit money 

laundering. Additionally, in August 2021, Fiat Chrysler Automobiles US LLC, located in Detroit, 

Michigan, was sentenced after the company pleaded guilty to conspiracy to violate the Labor 

Management Relations Act.

A total of 14 UAW defendants and Fiat Chrysler have been sentenced and ordered to pay $2,385,056 in 

restitution, $30,090,500 in fines, and $1,912,757 in forfeiture stemming from the investigations and 

prosecutions to date. 

Former Union Officer Sentenced to Prison for Embezzlement

In January 2021, Edward C. Davis, Jr., former Secretary-Treasurer of Brotherhood of Locomotive 

Engineers and Trainmen Division 620, located in Fort Worth, Texas, was sentenced to six months of 

prison and three years of supervised release. He was also ordered to pay $61,386 in restitution. In 

September 2020, Davis pleaded guilty to embezzlement of union funds. The OLMS investigation found 

that Davis wrote himself 86 unauthorized checks for additional salary and the purchase of a personal 

laptop.

Former Union Officer Sentenced for Taking Money within Special Maritime and Territorial 

Jurisdiction of the United States

In February 2021, Jeffrey Phillips, former Secretary-Treasurer of International Association of 

Machinists and Aerospace Workers Local Lodge 836, located at the Portsmouth Naval Shipyard in 

Kittery, Maine, was sentenced to two years of probation. He was also ordered to pay $57,611 in 

restitution, a $2,400 fine, and a $100 special assessment. In February 2020, Phillips pleaded guilty to 

taking and carrying away personal property within the special territorial jurisdiction of the United States. 
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The OLMS investigation uncovered that Phillips stole union funds by making two to three cash 

withdrawals of $500 at a bank drive-through window each week for nearly five years. 

Former Union Officer Sentenced for Embezzling Over $101,000 through Bank Fraud

In March 2021, Kenneth Morris, former Treasurer of American Federation of Teachers Local 2240, 

located in Kentfield, California, was sentenced to time served and three years of supervised release. He 

was also ordered to pay $101,583 in restitution and a $100 special assessment. In November 2019, 

Morris pleaded guilty to one count of bank fraud. Morris, a teacher at a Catholic school, embezzled the 

money by depositing dues deduction checks from the Archdiocese of San Francisco and the Diocese of 

San Jose into his personal account. He also wrote unauthorized checks to himself from the union bank 

account and deposited them into his personal bank account.

Former Union Officer Sentenced to Prison for Wire Fraud for Embezzling $185,000

In July 2021, Aja Jasmin, former President of United Food and Commercial Workers Local 350-C, 

located in Rancho Cucamonga, California, was sentenced to 28 months of imprisonment and three years 

of supervised release. She was ordered to pay $185,000 in restitution and a $25 special assessment. In 

February 2021, Jasmin pleaded guilty to one count of wire fraud. The investigation found that 

throughout a multi-year scheme, Jasmin took sole custody of the union’s checkbook, forged the 

signatures of the other account signatories on hundreds of checks, and wired funds from the local’s bank 

account to her personal credit cards for personal expenses. Jasmin prolonged the embezzlement scheme 

by submitting falsified bank statements to the international union, failing to provide relevant records for 

attempted audits, preventing new officers from reviewing the union’s financial records, and announcing 

fabricated account balances at membership meetings. The investigation was conducted jointly with the 

Department of Labor’s Office of Inspector General.

Former Union Employee Sentenced for Embezzling Over $112,000

In August 2021, Karen Pierce, former office manager for Plumbers Local 142, located in San Antonio, 

Texas, was sentenced to five years of probation and ordered to pay $112,759 in restitution. In July 

2020, Pierce pleaded guilty to one count of theft of union funds. The OLMS investigation found that 

Pierce embezzled money through stolen checks and used signature stamps to forge the officers’

signatures on most of the checks. She also falsified records in an attempt to conceal these thefts.

Former Union Officer Sentenced to Prison for Embezzling Over $140,000

In September 2021, Hasan Zahdeh, former President of Michigan Union of Healthcare Workers, located 

in Muskegon, Michigan, was sentenced to 14 months of imprisonment followed by three years of 

supervised release. He was also ordered to pay $140,498 in restitution and a $100 special assessment. 

In April 2021, Zahdeh pleaded guilty to one count of embezzlement of union funds. The OLMS 

investigation discovered that Zahdeh used the embezzled funds to pay for hundreds of personal and 

unauthorized expenses, such as international travel including several trips to Turkey, utility bills, home 

repairs and maintenance, furniture, and various communications bills. In addition, he wrote four checks 

to the union’s attorney, forged the attorney’s signature on the back of the checks, and deposited the

checks into his personal bank accounts. Zahdeh also stole dues payments from members by depositing 
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dues checks into his personal bank account as well as by directing members to deposit their individual 

dues payments into a newly opened personal bank account, which he misrepresented to members as a 

union bank account.

Former Union Officer Sentenced to Prison Following Union Book Selling Scheme

In June 2019, Salvatore Tagliaferro, former President of Carpenters Local 926, located in Brooklyn, 

New York, and a New York City District Council of Carpenters Representative, and John DeFalco, 

former Vice President of Carpenters Local 157, located in New York, New York, were indicted on 

multiple charges for a scheme to sell union “books” or membership cards (union property) in exchange 

for cash bribes. In October 2020, DeFalco pleaded guilty to embezzlement/conversion of union assets 

and aiding and abetting, conspiracy, honest services wire fraud, as well as other crimes including 

witness tampering. DeFalco continues to await sentencing. In April 2021, Tagliaferro was found guilty 

following a jury trial of all charges he faced: conversion of union assets, honest services wire fraud, 

aiding and abetting, and conspiracy. In September 2021, Tagliaferro was sentenced to five years in 

prison and ordered to pay $145,065 in restitution and $296,400 in forfeiture. The investigation was 

conducted jointly with the United States Attorney’s Office for the Southern District of New York -

Public Corruption Unit, the Department of Labor’s Office of Inspector General, and the New York City 

Department of Investigation.

Former Union Officer Sentenced to Prison for Embezzling Over $184,000

In September 2021, Yvette Luster, former Treasurer of Postal Mail Handlers Local 314, located in 

Hazelwood, Missouri, was sentenced to 18 months of prison and three years of probation. Luster was 

also ordered to pay $184,138 in restitution and a $100 special assessment. In June 2021, Luster pleaded 

guilty to one count of embezzlement of labor union assets. The OLMS investigation found that Luster 

embezzled by making over $80,000 in ATM cash withdrawals and by using the union’s debit card for 

numerous personal and unauthorized disbursements. She also embezzled by submitting numerous 

claims for lost work time paid by the United States Postal Service and by paying herself duplicate 

unauthorized salary payments. Luster used the embezzled funds to pay for personal expenses.

2. Protecting Union Democracy

Title IV of 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 member voting rights. While the majority of union officer elections are held without 

protest, OLMS investigates properly-filed complaints protesting union officer elections. Before filing a 

complaint with OLMS, union members must avail themselves of the union’s internal protest procedures. 

If OLMS’ investigation reveals a violation of Title IV of the LMRDA that may have affected the 

outcome of the election, OLMS seeks a voluntary compliance agreement with the union to allow OLMS 

to supervise a new election. If the union does not voluntarily agree to remedy the violation, OLMS 

takes legal action seeking to void the challenged election and conduct a new election supervised by 

OLMS. Under Title III of the LMRDA, 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.
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OLMS seeks to improve the timely resolution of union officer election complaints, which is measured 

by the average number of elapsed days between the receipt of a complaint and its resolution. As seen in

the chart below, in 2021 OLMS achieved its elapsed time performance goal of 67 days by reducing the 

average number of elapsed days to resolve union officer election complaints to 66.9 days. OLMS 

tracks the number of election investigations and supervised elections, both of which are dependent upon 

the number of election complaints OLMS receives. The 2021 planning projections in those categories 

were based on historical averages only. OLMS does not project or estimate the number of lawsuits 

filed or voluntary compliance agreements obtained in a year, given that these actions are dependent 

upon the facts of each case.

OLMS Performance Goal – Union Democracy FY 2021 Target FY 2021 Results

Number of Days to Resolve Election Complaints 67 66.9

 OLMS Enforcement Statistics – Union Democracy FY 2021 Plan FY 2021 Results

Election Investigations Conducted 96 78

Lawsuits Filed N/A 8

Voluntary Compliance Agreements Obtained N/A 14

Supervised Elections Completed 26 27

Trusteeship Investigations 9 17

The 78 election complaints OLMS received in 2021 represent 1.1% of the 7,000 elections that OLMS 

estimates unions held in 2021, and the 27 supervised rerun elections (i.e., elections in cases in which the 

union acknowledged, or a court found, that there were violations) represents 34.6% of the complaints 

filed and 0.39% of all union officer elections conducted. 

The following highlights significant OLMS election cases during FY 2021.

Department Files Suit Against AFGE Local 96

In June 2021, the Department filed suit against American Federation of Government Employees (AFGE) 

Local 96, located in St. Louis, Missouri. The complaint alleged that the local failed to elect the winning 

candidate by a majority of votes cast, as required by the AFGE Constitution. During the union’s 2020 

election, Local 96 failed to hold a runoff between the two remaining candidates after a third candidate 

was declared ineligible, and no candidate received a majority of the votes cast. The lawsuit followed an

election conducted under the supervision of the Department pursuant to a voluntary compliance 

agreement with Local 96. Local 96 failed to complete the supervised election process after an

investigation found that one candidate’s campaign materials were created with support from a local 

employer. The litigation is pending.
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New York Professional Nurses Union Agrees to Hold New Election Under OLMS Supervision

In March 2021, OLMS entered into a voluntary compliance agreement with the New York Professional 

Nurses Union, located in New York, New York, concerning its regular election of officers in October 

2020. The union agreed to hold a new election for the offices of the vice president and seven executive 

board members under the supervision of OLMS. The investigation concluded that the union failed to 

mail notice of the election to the last known home address of all members at least 15 days prior to the 

election, denied new members the right to vote despite their having met the requirements for 

membership, and failed to provide adequate safeguards to ensure a fair election when it did not provide 

any advance notice of a change in its eligibility rules with respect to members who were in arrears after 

a leave of absence. The supervised election will take place by polling site and absentee ballot in January 

2022.

Communications Workers Local 6222 Agreed to Hold New Election Under OLMS Supervision

In April 2021, OLMS entered into a voluntary compliance agreement with Communications Workers of 

America Local 6222, located in Houston, Texas, to conduct a new election and installation for the 

offices of president, vice presidents II and III, and secretary-treasurer, along with executive board 

positions for AT&T Mobility (Call Center) and ASI, on or before June 2021, under OLMS supervision. 

The investigation established that the local failed to provide adequate safeguards when it used a ballot 

drop box that was left unattended and unsecured at the union hall during the election period and by 

failing to properly count ballots, which resulted in an incorrect candidate being advanced to the runoff 

election for secretary-treasurer. Additionally, campaign literature was posted on AT&T company 

vehicles. The June 2021 supervised election and August 2021 run-off election were both held by mail 

ballot.

Settlement Agreement Ends Litigation Involving Auto Workers Local 2209 Election

In April 2021, the Department filed suit against United Automobile, Aerospace and Agricultural 

Implement Workers of America Local 2209, located in Roanoke, Indiana. The complaint alleged that 

the union applied one or more candidate qualifications that were unreasonable because they were not 

specifically contained in the UAW constitution and bylaws, were not uniformly applied, and denied a 

member in good standing the right to be a candidate. In June 2021, the union entered into a settlement 

agreement with OLMS directing that the agency would supervise a new election for the office of Unit I 

Chairperson. The election concluded with in-person polling at three locations over the course of a 24-

hour period in July 2021.

Union of Patriots Plaza Agreed to Hold New Election under OLMS Supervision

In April 2021, OLMS entered into a voluntary compliance agreement with Union of Patriots Plaza, 

located in Pikesville, Maryland. The union agreed to conduct nominations, election, and installation for 

the offices of president, vice president, secretary-treasurer and recording secretary under OLMS 

supervision. The investigation concluded that the union has been in existence since at least September 

2016 and had failed to conduct an election of officers in violation of the LMRDA and the union’s 

constitution and bylaws. The supervised election, conducted by polling site with an absentee ballot 

provision, was concluded in July 2021. 
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Settlement Agreement Ends Litigation Involving AFGE District 4 Election

In April 2021, the Department filed suit against the American Federation of Government Employees 

(AFGE), located in Washington, D.C. The suit sought to nullify AFGE’s election for the office of 

National Vice President for District 4, one of the positions in the October 2020 AFGE District 4 caucus 

election. The complaint alleged that AFGE violated Title IV of the LMRDA by failing to follow its 

constitution and bylaws and failing to provide adequate safeguards to ensure a fair election when one 

local union cast the incorrect number of votes in the election. The complaint further alleged that AFGE 

failed to follow its constitution and bylaws when it improperly allocated a local union’s votes to two 

delegates, after that local improperly denied a third, duly elected delegate’s request to attend the 2020 

District 4 caucus. A July 2021 stipulated settlement states that a new election for District 4 national vice 

president will be conducted under OLMS supervision. The District 4 Caucus concluded in December 

2021 via a polling site election with local delegates from District 4.

Letter Carriers Branch 142 Agreed to Hold New Election Under OLMS Supervision

In June 2021, OLMS entered into a voluntary compliance agreement with National Association of Letter 

Carriers Branch 142, located in Washington, D.C. The union agreed to conduct a new election and 

installation for the office of president under OLMS supervision. The investigation concluded that a 

union list was used by one of the candidates to send campaign text messages, and that the list was not 

provided to the other candidates. The supervised election, conducted by mail ballot, concluded in 

August 2021.

AFGE Agreed to Hold Rerun Election for District 7 National Vice President

In June 2021, OLMS entered into a voluntary compliance agreement with the American Federation of 

Government Employees (AFGE), located in Washington, D.C., concerning AFGE District 7’s October 

2020 election of union officers. AFGE agreed to hold a new election for the office of District 7 National 

Vice President. The OLMS investigation concluded that the District 7 Caucus Credentials Committee 

seated some delegates with incomplete credentials and seated other delegates from locals that had failed 

to provide proper notice of the delegate election to their members, which resulted in ineligible delegates 

being permitted to vote. The investigation also determined that one candidate used a union cell phone to 

send text messages and make phone calls to campaign. In addition, the investigation found that District 

7 failed to elect its officers by secret ballot as required by the AFGE Constitution when it utilized an 

internet voting system that made it possible to connect some delegates with their votes by analyzing 

local voting strength and number of delegates.

Department Files Suit Against Teamsters Local 688

In July 2021, the Department filed suit against International Brotherhood of Teamsters Local 688, 

located in St. Louis, Missouri. The lawsuit sought to nullify the union’s November 2020 officer election 

and order Local 688 to conduct a new election with new nominations under OLMS supervision. The 

complaint alleged that Local 688 failed to provide adequate safeguards and ensure ballot secrecy during 

the election when the union failed to provide physical partitions, failed to instruct members to vote in 
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secret, and allowed for multiple members to vote while seated at the same table. The lawsuit is still 

pending.

Department Files Lawsuit against Electrical Workers Local 108

In August 2021, the Department filed suit against International Brotherhood of Electrical Workers Local 

108, located in Tampa, Florida. The lawsuit sought to nullify the local’s September 2020 election for 

the offices of business manager/financial secretary, president, and convention delegate. The complaint 

alleged that the local failed to provide absentee ballots to all the members who requested one. The 

OLMS investigation revealed that the United States Postal Service assigned the local a post office box 

that was rented to and accessed by a different customer throughout the election period. Since the local 

used that post office box as the address for all absentee ballot requests, such requests were returned to 

members as undeliverable, denying members the right to vote. The investigation also established that 

the union’s failure to provide absentee ballots may have affected the outcome of the election. A 

December 2021 stipulated settlement provided for new nominations and a new election to be conducted 

for the offices of president, business manager/financial secretary, and three convention delegates under 

OLMS supervision.

3. Labor Union and Labor-Management Transparency

The LMRDA is predicated on the principle that union members, officers, and the general public benefit 

by having access to information about labor unions, their officers and employees, employers, labor 

relations consultants, and surety companies. To this end, OLMS administers a comprehensive 

reporting and disclosure program. OLMS also offers compliance assistance sessions for union 

members and officials on the financial reporting obligations under the LMRDA. 

Title II of the LMRDA requires that unions file annual financial reports, known as Labor-Management 

(LM) Reports (Forms LM-2, LM-3, LM-4, or simplified filings), with OLMS. Unions must also file 

trusteeship reports (Forms LM-15, LM-16) when they establish supervision or control over a 

subordinate body. Other entities, such as employers (Form LM-10), labor relations consultants (Forms 

LM-20, LM-21), union officers and employees (Form LM-30), and surety companies (Form S-1), are 

also required to file reports under certain circumstances. Reports are available for public disclosure on 

the OLMS Online Public Disclosure Room website, www.unionreports.gov. OLMS also collects and 

maintains collective bargaining agreements (CBAs) filed by CBA signatories on a voluntary basis. 

These CBAs also are located on the OLMS website. 

During FY 2021, OLMS established an initiative to improve disclosure of arrangements made between 

employers and labor consultants, as required under the LMRDA. OLMS planned to process a 

combined 600 Form LM-10 employer reports and Form LM-20 consultant reports to disclose

employer-consultant agreements or arrangements to persuade employees to exercise or not to exercise

their rights to organize and engage in collective bargaining. While improving the transparency of these 

arrangements over the previous year, OLMS fell short of its plan and only processed a total of 480 

employer and consultant reports during FY 2021.

OLMS received, processed, and made the following reports publicly available in FY 2021. 
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OLMSLMRDAReports Administration FY 2021

Form LM-1 Labor Organization Information Reports 203

Form LM-2 Labor Organization Annual Reports 4,799

Form LM-3 Labor Organization Annual Reports 10,049

Form LM-4 Labor Organization Annual Reports 6,494

Simplified Labor Organization Annual Reports 1,134

Form LM-10 Employer Reports 403

Form LM-15 Trusteeship Reports (initial, semiannual, and 15A) 295

Form LM-16 Terminal Trusteeship Reports 50

Form LM-20 Labor Relations Consultant Agreement and Activities Reports 314

Form LM-21 Labor Relations Consultant Receipts and Disbursements Reports 56

Form LM-30 Labor Organization Officer and Employee Reports 420

Form S-1 Surety Company Annual Reports 59

Total Reports 24,276

OLMS utilizes a web-based Electronic Forms System (EFS) for completing and submitting LM 

reports. Implementation of EFS is being conducted in phases. Currently, Form LM-1, LM-2, LM-3, 

and LM-4 Labor Organization reports, Form LM-10 Employer Report, Form LM-20 and LM-21 labor 

relations consultant reports, and Form LM-30 Labor Organization Officer and Employee reports can be 

filed via EFS. EFS allows any of these filers with a web-enabled computer to complete and 

electronically submit an LM report without any special software or a digital signature. EFS performs 

calculations for the LM report and completes a form error check prior to submission to OLMS. EFS 

also allows unions that maintain electronic accounting records to import financial data from their 

accounting programs directly into their LM form. When labor organization annual reports are not filed 

in a timely manner or the reports filed are deficient, OLMS opens an investigation to obtain 

compliance. Additionally, when reports due from employers, labor relations consultants, and union 

officers and employees are not timely or properly filed, OLMS pursues delinquent and deficient reports 

from these entities, known as “Special Reports” cases. 

During FY 2021, 100 percent of LM-2, LM-3, and LM-4 filers submitted their annual reports via EFS, 

which has increased timely and accurate filing. Additionally, nearly 42 percent of LM-30 reports were 

filed electronically while 93 percent of LM-10 reports were filed using EFS, both representing 

increases in electronic filing in these areas over last year. In 2021, OLMS exceeded its performance 

goal by increasing the percent of all LM reports filed electronically to 97.4 percent. OLMS tracks the 

numbers of delinquent and deficient reports and special reports cases completed. The 2021 planning 

projections in those categories are largely based on historical averages. 
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 OLMSPerformanceGoal – Reporting and Disclosure FY 2021 Target FY 2021 Results

Percent of Reports Filed Electronically 85% 97.4%

OLMSEnforcement Statistics – Reporting and Disclosure FY 2021 Plan FY 2021 Results

LM-2/3/4 Delinquent Reports Cases Completed 1,514 1,836

LM-2/3/4 Deficient Reports Cases Completed 151 177

Special Reports Cases Completed 61 70

4. Employee Protections

OLMS also administers responsibilities under federal transit law by ensuring that fair and equitable 

arrangements protecting mass transit employees are in place before the release of federal transit 

assistance. When federal funds are used to acquire, improve, or operate a transit system, federal law 

requires that arrangements must be made to protect the rights of affected mass transit employees. 

These arrangements must be approved by OLMS before the U.S. Department of Transportation’s 

Federal Transit Administration (FTA) can release funds to mass transit employers. 

In FY 2021, OLMS certified employee protections for 1,985 federal transit grants. With the exception 

of one grant application, OLMS certified 100 percent of grants within a 45-day timeframe, well under 

the 60 days permitted by guidelines (29 CFR §215). Pursuant to 29 CFR §215.7, OLMS notified 

unions and the public of 330 rural grants, to which the FTA applied the Special Warranty 

Arrangement. More information about employee protections under federal transit law can be found on 

the OLMS website. 

5. Regulatory Initiatives

OLMS published, on March 6, 2020, a final rule establishing a Form T-1 Trust Annual Report that 

requires annual reporting by Form LM-2 filing labor organizations on financial information pertinent to 

“trusts in which a labor organization is interested” (“section 3(l) trusts”). The rule required a labor 

organization with total annual receipts of $250,000 or more to file a Form T-1, under certain 

circumstances, for each section 3(l) trust, as defined by 29 U.S.C. § 402(l) of the LMRDA. Under this 

rule, the Form T-1 reporting requirements were triggered if a labor organization, either alone or in 

combination with other labor organizations, (1) selected or appointed the majority of the members of 

the trust’s governing board, or (2) contributed more than 50 percent of the trust’s receipts. 

Subsequently, on March 29, 2021, OLMS announced that, in the spring 2021 Semi-Annual Regulatory 

Agenda, it would publish notice of an intended rulemaking to propose rescission of the Form T-1. 

Additionally, OLMS announced that it would not seek to enforce the filing of a Form T-1 for one year 

from the date a labor organization’s first Form T-1 is due. See: 

https://www.dol.gov/agencies/olms/about/newsletter/2021/1. 

Later, on May 27, 2021, OLMS published a notice of proposed rulemaking (NPRM) to rescind the Form 

T-1. Upon further review of the 2020 Form T-1 rule, including the pertinent facts and legally relevant 
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policy considerations surrounding that rulemaking, OLMS proposed to withdraw the rule implementing 

the Form T-1 because it believed that the trust reporting required under the rule is overly broad and is 

not necessary to prevent the circumvention and evasion of the LMRDA Title II reporting requirements. 

Moreover, upon further consideration, the Department expressed concern that the 2020 rulemaking 

record was insufficient to justify the separate trust reporting requirements as set forth in the 2020 Form 

T-1 rule. The NPRM had a 60-day comment period that closed on July 26, 2021. Please see the OLMS 

Form T-1 filing advisory. 

6. Compliance Assistance

In FY 2021, OLMS undertook the following initiatives as part of a comprehensive compliance 

assistance program to educate unions, union officials, employers, and consultants about the LMRDA:

• OLMS continued its program of structured, nationwide compliance assistance seminars, but sought 

to reduce the number of sessions while increasing attendance through enhanced recruitment. 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 the compliance assistance 

seminar is similar throughout the country so that every officer in attendance benefits from the same 

material. In 2021, OLMS conducted more virtual compliance assistance seminars than normal due 

to COVID-19 in an effort to increase participation. For example, OLMS sponsored national 

compliance assistance seminars, presented in both English and Spanish, providing guidance on 

holding union officer elections during the pandemic. In total, OLMS provided formal compliance 

assistance seminars to 3,730 participants and recorded 8,252 contact hours (i.e., the number of 

participants multiplied by the number of hours of instruction). 

• OLMS continued to be responsive to all specific requests for compliance assistance seminars. 

OLMS also received and responded to hundreds of requests for information and interpretations. 

• OLMS continued to work with the nation’s most prominent international and national unions in the 

Voluntary Compliance Partnership (VCP) initiative, leveraging their resources to improve the 

compliance performance of over 16,000 affiliates in 2021. During FY 2021, the VCP program 

expanded to 47 partner national/international unions. VCP continued to solidify its platform as a 

national compliance assistance effort focused on improving timely reporting, bonding coverage, 

accurate and complete reporting including the submission of union constitutions and bylaws, and 

the implementation of financial safeguards to prevent unions from becoming victims of financial 

fraud. VCP is a strategic leadership effort that requires executive level involvement from OLMS 

and officer level involvement from the union, which helps to drive compliance through the labormanagement community by providing tools, information, and assistance. The overall late-filing 

rate for unions under the VCP initiative is significantly lower than for non-VCP unions, and the late 

filing rate decreased significantly after increasing during FY 2020, as the COVID-19 pandemic 

began. VCP continues to assist labor organizations with OLMS procedures regarding mergers and 

terminations, regional and national training conferences, and other organizational development 

activities. OLMS leadership met directly with the presidents and secretary-treasurers of 23 VCP 

member unions in 2021. The initiative generated 77 compliance assistance contact hours and 

distributed comprehensive annual VCP informational reports, specifically tailored for each of 30

different VCP international and national unions.
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• OLMS reinstituted its Persuader Reporting Orientation Program (PROP), a compliance assistance 

initiative to inform employers and their representatives about potential reporting obligations under 

the LMRDA. The PROP initiative was in effect previously from 2011 to 2016. PROP enables 

OLMS to contact employers involved in representation elections – and any other parties that have 

notified the National Labor Relations Board of their status as representatives for such employers –

to inform them of potential LMRDA reporting requirements. OLMS provides information on 

where to locate reporting forms and instructions and how to contact OLMS to ask questions or 

receive additional information. OLMS also provides a fact sheet on employer-consultant 

agreements.

• OLMS managed a public email address, enabling it to respond to nearly 2,400 inquiries and 

requests in the year. 

• OLMS continued its Labor Organization Orientation Program, which distributed 99 information 

letters to newly registered labor organizations. 

7. Outreach

In 2021, OLMS embarked on a project to educate workers, unions, policy makers and the public more 

broadly about OLMS’ work and the important role labor unions play in the modern American economy. 

These efforts include:

• A redesigned website to better describe the results of OLMS’ enforcement activities in the broader 

context of the labor movement and the enforcement activities of other Department of Labor worker 

protection agencies.

• A series of blog posts by the OLMS Director under the website headline “From the Director’s 

Desk” discussing these and other topics in a more narrative form.

• Presentations on these topics (in person and virtually) by the Director to the regulated community.

• Conducting (in coordination with other DOL agencies) empirical research into topics including the 

role of “persuaders” in union representation elections, and the leveraging of OLMS and other data 

to better understand the race, ethnicity and gender wage gap between union and non-union workers 

and industries.

• Participation in work undertaken by the Department in connection with the White House Task 

Force on Worker Organizing and Empowerment.