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Introduction

When the Labor-Management Reporting and Disclosure Act (LMRDA) was enacted in 1959, 

Congress declared, “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. The Office of Labor-Management Standards (OLMS) continues today to 

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

The major provisions of the LMRDA, by title, are: 

• 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

• Title V: Safeguards for protecting union funds and assets

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’ Division of Statutory Programs 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 enforcing the LMRDA through its criminal and 

civil investigations. Criminal investigations include embezzlement, deprivation of rights by 

violence, extortionate picketing, willful failure to file reports, filing false reports, prohibited 

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

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

financial disclosure requirements, and trusteeship standards.

OLMS conducts 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. 

2013 Annual Report

Office of Labor-Management Standards

U.S. Department of Labor

Michael J. Hayes, Director 

January 2014
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Compliance assistance also plays a central role in the OLMS enforcement strategy. OLMS has 

an active compliance assistance program to promote voluntary compliance with the LMRDA by 

informing union officers and employees of their responsibilities and informing members of 

their legal rights.

Summary

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

• Section 1 presents key FY 2013 criminal enforcement and performance results pursuant to 

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

criminal enforcement actions. A more complete listing of these actions is located at 

www.dol.gov/olms/regs/compliance/enforce_2013.htm on the OLMS website.

• Section 2 presents key FY 2013 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 FY 2013. Listings of union officer 

election voluntary settlement agreements are located at 

www.dol.gov/olms/regs/compliance/civil_actions_2013.htm (2013). Final decision letters 

in election and trusteeship cases are located on the OLMS website at 

www.dol.gov/olms/regs/compliance/OLMS_FOIA.htm.

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

LMRDA Title II (reporting requirements). Section 3 also presents key FY 2013 reporting 

enforcement and performance results. Reports are available for public disclosure on the 

OLMS Online Public Disclosure Room website, www.unionreports.gov.

• Section 4 summarizes grant certification activity pursuant to Section 13(c) of the Federal 

Transit Act, ensuring fair and equitable arrangements protecting mass transit employees.

• Section 5 briefly describes compliance assistance activities conducted in FY 2013.

To view past-year OLMS annual reports, visit: 

www.dol.gov/olms/regs/compliance/OLMS_Annual_Reports.htm.

Program Activities

1. Safeguarding Union Assets

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

possible embezzlement from unions and other violations of criminal laws. OLMS also conducts 

audits of labor unions to detect embezzlement and ensure and promote compliance with the 

LMRDA. Compliance audit closing letters are located on the OLMS website at 

www.dol.gov/olms/regs/compliance/CA_closing_letters.htm. OLMS seeks to more 

effectively and accurately identify cases of fraud and embezzlement, with effectiveness 

measured by the percent of audits resulting in the opening of a “fallout” criminal case. 
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In FY 2013, OLMS exceeded its performance goal by increasing the fallout rate to 20.97 percent. 

By increasing the percent of audits that result in criminal case fallouts, OLMS was able to 

redirect resources from audits to its criminal investigation program. Thus, despite reduced 

agency resources, OLMS still exceeded its planned numbers of criminal cases processed and 

reached historical levels in criminal convictions. 

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. A union 

officer or employee who embezzles or misappropriates union funds or assets commits a federal 

crime punishable by imprisonment or fine, or both. OLMS is responsible for investigating these 

crimes. The following are some of the most significant criminal enforcement actions from FY 

2013.

Former Union Employee Convicted of Embezzling over $104,000

In October 2012, Rachel Lanham, former office secretary for Machinists District Lodge 34 in 

Columbus, Ohio, was sentenced to six months of home confinement, three years of supervised 

release, and was ordered to make full restitution in the amount of $104,867. In June 2012, 

Lanham pled guilty to one count of embezzlement. The investigation found that Lanham made 

unauthorized salary payments to herself via electronic fund transfers and used a union credit 

card to make unauthorized personal purchases.

Former Union Secretary-Treasurer Sentenced for Wire Fraud

In October 2012, Rebecca Mercer, former Secretary-Treasurer of National Treasury Employees 

Union (NTEU) Chapter 284 in Atlanta, Georgia, was sentenced to one year and one day of 

imprisonment, three years of probation, and was ordered to pay restitution in the amount of 

$50,822. In June 2011, Mercer pled guilty to one count of wire fraud. The investigation revealed 

that between July 2006 and June 2008, Mercer embezzled more than $50,000 in union funds 

through unauthorized debit card transactions and ATM withdrawals. 

Former Union Official Sentenced for Conspiring to Embezzle Union Funds

In October 2012, Ronald Witt, former business manager and JATC Trustee of International 

Union of Operating Engineers (IUOE) Local 450 in Houston, Texas, was sentenced to one year 

and one day in prison, three years of supervised release, and was ordered to pay $198,333 in 

restitution. In January 2012, Witt pled guilty to one count of conspiring to embezzle union 

funds. Witt stole nearly $200,000 and used the money to pay for luxury trips for himself and 

friends, to remodel his home, and for other personal expenses. Witt’s wife, Anita Witt, former 

OLMS Performance Goal – Financial Integrity FY 2013 Target FY 2013 Results

Percent of Audits Resulting in a Criminal Case 14.25% 20.97%

OLMS Enforcement Statistics – Financial Integrity FY 2013 Plan FY 2013 Results

Criminal Cases Processed 296 319

Indictments 100 97

Convictions 100 116

Compliance Audits Conducted 321 329
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Local 450 Financial Secretary and the committee’s coordinator, was also charged with 

conspiracy and embezzlement from an employee benefit plan. Those charges were dismissed 

following the acceptance of responsibility and sentencing of her husband as agreed to in Ronald 

Witt’s plea agreement. This investigation was conducted jointly with the Employee Benefits 

Security Administration.

Former Union Official Sentenced for Embezzling over $110,000 via Fraudulent Checks

In December 2012, Claude Huff, former President and Business Manager of Amalgamated 

Transit Union (ATU) Local 1385 in Dayton, Ohio, was sentenced to five years of probation and 

was ordered to pay restitution in the amount of $110,348. In September 2012, Huff pled guilty 

to one count of embezzlement of union funds. The investigation disclosed that between 2004 

and 2010, Huff embezzled union funds through unauthorized checks to himself for salary, 

vacation pay, and sick leave. Huff also altered union financial records in an attempt to conceal 

his actions.

Former Union Trustee Sentenced to Prison for Embezzling $379,000

In January 2013, Ava Ramey, former trustee of United Government Security Officers of America 

(UGSOA) Local 21 in Bowie, Maryland, was sentenced to two years in prison followed by three 

years of probation. She was also ordered to pay restitution and forfeiture in the amount of 

$379,000. In June 2012, Ramey pled guilty to one count of embezzlement from a labor 

organization. The investigation revealed that between December 2005 and October 2009, 

Ramey wrote more than $80,000 in checks from the union’s account to either herself or to cash 

for personal expenses and withdrew more than $60,000 from the union’s account in 

unapproved ATM withdrawals. In addition, Ramey withdrew in person or transferred to her 

personal account more than $100,000 in union funds and wrote more than $60,000 in checks 

from the union’s account to her family members.

Former Union President Sentenced to Prison for Embezzlement of $150,000

In February 2013, John McNamee, former President of International Alliance of Theatrical Stage 

Employees (IATSE) Local 829 in New York, New York, was sentenced to one year of 

imprisonment, two years of supervised release, and was ordered to pay a $25,000 

fine. McNamee made full restitution prior to the sentencing. In October 2012, McNamee pled 

guilty to one count of embezzlement in the amount of $150,000 in labor union funds. An OLMS 

investigation found that between January 2004 and February 2011, McNamee used the union 

credit card to cover personal expenses, including jewelry, clothing, restaurant bills, 

entertainment tickets, and vacations for himself and his family.

Former Union Official Sentenced to Home Detention for Embezzlement for Unauthorized 

Pay and Reimbursements

In February 2013, Lawrence E. Minas, former General Chairman for United Transportation 

Union (UTU) General Committee of Adjustment 449 in Munster, Indiana, was sentenced to six 

months of home detention and was ordered to pay 10% of his monthly income in restitution. In 

September 2012, Minas pled guilty to embezzling union funds in the amount of $71,160. The 

investigation discovered the embezzlement and false records relative to unauthorized salary 

reimbursements, per diem payments, and vacation reimbursements. Minas admitted guilt in a 

signed statement.
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Former Union Employee Sentenced to Prison and Ordered to Repay over $200,000 in 

Cash Dues Embezzled

In April 2013, Grace Rathke, former office manager for Laborers Local 32 in Rockford, Illinois, 

was sentenced to 17 months of incarceration, three years of probation, and was ordered to pay 

full restitution of $204,836. In January 2013, Rathke pled guilty to embezzling union funds. The 

investigation found that between November 2004 and March 2009, Rathke stole money that the 

union members paid in cash and falsified records to conceal the theft. This investigation was 

conducted jointly with the Department of Labor’s Office of Inspector General. 

Former Union President Sentenced to Jail for Embezzlement of Unauthorized Pay 

Totaling $110,000

In May 2013, Stephen P. Arena, former President of Novelty and Production Workers Local 148 

in Jersey City, New Jersey, was sentenced to six months in jail and six months home 

confinement for embezzlement of union funds. Arena agreed to make full restitution of 

$110,000 to the union and was ordered to pay a $5,000 fine to the court. In May 2012, Arena 

pled guilty to a one-count indictment charging him with embezzlement of labor union 

funds. Arena conspired with the union’s secretary-treasurer/recording secretary, David 

Caivano, to steal money from the union by taking unauthorized salary increases and 

bonuses. This investigation was conducted jointly with the Department of Labor’s Office of 

Inspector General.

Former Union Secretary-Treasurer Sentenced to Prison for Filing a False Report

In May 2013, Joseph Allen, former Secretary-Treasurer of National Association of Letter Carriers 

(NALC) Branch 588 in Athens, Georgia, was sentenced to one year in prison, one year of 

probation, and was ordered to pay restitution in the amount of $50,000. In March 2013, Allen 

pled guilty to one count of filing a false report. The investigation found that Allen took out a 

bank loan in the union’s name without authorization of the executive board or membership. 

Allen also used the union’s credit and debit cards for personal purchases and wrote 

unauthorized checks to himself and for personal purchases. This investigation was conducted 

jointly with the Department of Labor’s Office of Inspector General and U.S. Postal Service’s 

Office of Inspector General.

Former Union Employee Sentenced to Home Detention for Embezzlement

In June 2013, Deborah Small, former bookkeeper for International Brotherhood of Electrical 

Workers (IBEW) Local 712 in Beaver, Pennsylvania, was sentenced to 10 months of home 

detention, five years of probation, and was ordered to pay restitution in the amount of 

$75,285. The court ruled that the restitution should include the $19,800 in auditing fees incurred 

by the union after considering the victim impact statement and the financial losses to the 

union. In February 2013, Small pled guilty to one count of embezzlement in the amount of 

$55,485. The investigation disclosed that Small embezzled the money using a variety of 

methods: petty cash, extra salary checks, unauthorized health care reimbursements, and a 

complicated receipts scheme. 

Former HFIA Clerical Employee Sentenced to Prison for Embezzling over $500,000 in 

Unauthorized Checks

In July 2013, Cora Carper, former clerical employee for the International Association of Heat 

and Frost Insulators and Allied Workers (HFIAW) in Lanham, Maryland, was sentenced to 37 

months in prison followed by three years of probation. Carper agreed that the total 
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embezzlement amount was $502,586 and was ordered to pay the remaining restitution of 

$495,286. In April 2013, Carper pled guilty to embezzling at least $200,000 from the union. The 

investigation found that, between June 2009 and February 2011, Carper cashed more than 300 

checks from the union’s political action fund which she managed. Carper frequently falsified 

information on the checks and in the union’s electronic ledger in order to conceal the 

embezzlement.

Former Union Official Sentenced for Embezzling Cash Dues

In July 2013, Kristine Stephens, former administrative assistant and bookkeeper for Painters 

Local 567 in Sparks, Nevada, was sentenced to 10 months of home confinement with electronic 

monitoring, five years of probation, 100 hours community service, and was ordered to pay 

$81,570 in restitution. In November 2012, Stephens pled guilty to one count of 

embezzlement. The investigation found that Stephens stole cash dues from the union. 

Former International Union Employee Sentenced for Embezzling Union Funds

In July 2013, Charles E. Rocha, former Political Director for the Steelworkers International 

Union in Pittsburgh, Pennsylvania, was sentenced to two years of probation and was ordered to 

pay a fine of $2,000. Rocha had previously made restitution in the amount of $12,449. Rocha 

also filed a petition with the court to have the Section 504 bar that would prohibit him from 

serving in certain capacities with labor unions be reduced in length so that he could continue 

serving as a union consultant. The judge denied Rocha’s petition; therefore, the 13-year bar was 

automatically imposed. In March 2013, Rocha pled guilty to embezzling union funds. The 

investigation found that between January 2008 and June 2009, Rocha misused a union credit 

card, incurred personal travel agency charges, and received unauthorized expense 

reimbursements from falsified travel vouchers.

2. Protecting 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. When a union member files a timely 

complaint protesting a regularly scheduled election of union officers following a timely and 

proper internal protest, OLMS conducts an investigation. If the investigation reveals a violation 

of the union democracy provisions of the LMRDA that may have affected the outcome of the 

election, OLMS asks the union to agree to allow OLMS to supervise a new election. If the union 

agrees, a voluntary compliance agreement is signed. If the union does not voluntarily agree to 

remedy the violation, OLMS takes 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 seeks to improve the timely resolution of union officer election complaints, which is 

measured by the average number of elapsed days. In FY 2013, OLMS exceeded its performance 

goal by reducing the average number of elapsed days to resolve union officer election 

complaints to 71 days. OLMS tracks the number of election investigations and supervised 

elections, which are dependent upon the number of election complaints received by OLMS. The 

FY 2013 planning projections in those categories are based on historical averages. OLMS does 
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not project or estimate the number of lawsuits filed or voluntary compliance agreements 

obtained in a year, given that such actions are dependent upon the facts of each case.

OLMS Performance Goal – Union Democracy FY 2013 Target FY 2013 Results

Number of Days to Resolve Election Complaints 75 71

OLMS Enforcement Statistics – Union Democracy FY 2013 Plan FY 2013 Results

Election Investigations Conducted 123 122

Lawsuits Filed NA 8

Voluntary Compliance Agreements Obtained NA 19

Supervised Elections Completed 29 26

Trusteeship Investigations 6 15

The following highlights some of the most significant OLMS election cases during FY 2013.

Department Settled Lawsuit against Union General De Trabajadores

In February 2012, a stipulation of settlement was filed to resolve the Department’s March 2011 

lawsuit against the Union General De Trabajadores in Rio Piedras, Puerto Rico. The stipulation 

of settlement provided that the Department would supervise the union’s nomination and 

election of all officers no later than January 31, 2013. The lawsuit filed in the U.S. District Court 

for the District of Puerto Rico sought to set aside the union’s January 2010 election because the 

investigation established that employer funds were used to promote the winning slate in that an 

employer provided the winning slate with advertising and design services without being paid 

until after the investigation. OLMS supervised in-person polling for the 15,000-member union 

at four polling centers on one day with the tally conducted the following day in January 2013.

AFGE Local 1120 Enters into a Voluntary Compliance Agreement with OLMS

In November 2012, OLMS entered into a voluntary compliance agreement with American 

Federation of Government Employees (AFGE) Local 1120 in Boise, Idaho, concerning the 

challenged election in June 2012. The union agreed to conduct a new runoff election and 

installation for the office of president under OLMS supervision. The investigation established 

that Local 1120 failed to elect by secret ballot when the identity of members casting ballots using 

the union’s internet electronic voting system could be linked with their vote and the vote of a 

member who cast a ballot by mail could be easily identified. Additionally, the union did not 

provide candidates the opportunity to have observers at each stage of the election process since 

the election was conducted outside of the local union’s jurisdiction using an electronic voting 

system. The supervised election took place in February 2013 by mail ballot.

Steelworkers Local 13 Agrees to Hold New OLMS Supervised Election

In November 2012, OLMS entered into a voluntary compliance agreement with Steelworkers 

Local 13 in Independence, Missouri, concerning the challenged election of officers conducted in 

April 2012. The union agreed to conduct new nominations and a new election for the position 

of vice president as well as a new election for the positions of president, financial secretary, 

guide, and two guards under OLMS supervision. The investigation disclosed that Local 13 did 

not adequately update member address information, did not use an accurate voter eligibility 
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list, failed to verify that eligible members only voted once, failed to keep a record of why some 

ballots were invalidated and not opened or counted, unreasonably imposed a candidacy 

requirement and failed to notify candidates of enforcement of this requirement until after 

nominations, and improperly voided five ballots in their entirety. The supervised election was 

conducted in February 2013 by mail ballot.

IATSE Local 884 Enters into a Voluntary Compliance Agreement with OLMS

In January 2013, OLMS entered into a voluntary compliance agreement with Studio Teachers 

and Welfare Workers of the International Alliance of Theatrical Stage Employees (IATSE) Local 

884 in Los Angeles, California, to conduct a new election for the office of business

representative under OLMS supervision. The investigation established that Local 884 failed to 

consistently apply an election rule deadline related to postmarks on voted ballots. 

Additionally, the union failed to ensure adequate election safeguards when the election 

chairperson mailed ballots without observers or other election committee members present,

kept voted ballots at her home in an unsecured shoebox, and recounted the ballots and changed 

the winning margin in the sergeant-at-arms race without observers or other committee

members present. The supervised mail ballot election was held in April 2013.

Department Settled Lawsuit against United Steelworkers of America Local 1104

In February 2013, a stipulation of settlement was filed to resolve the Department’s October 2012 

lawsuit against United Steelworkers of America Local 1104 in Lorain, Ohio. The lawsuit filed in

the U.S. District Court for the Northern District of Ohio sought to set aside the union’s April 

2012 election because the Department’s investigation established that Local 1104 applied an 

unreasonable meeting attendance requirement which disqualified more than 95 percent of the 

members from running for elected office and resulted in only one contested race. The 

Department supervised new nominations and a new election for the offices of president, trustee 

(three positions), inside guard, and outside guard. The supervised election and tally for the 

1,200-member union were held at the local’s union hall in April 2013.

Western Pulp and Paper Workers Local 5 Enters into Voluntary Compliance Agreement 

with OLMS 

In March 2013, the Department entered into a voluntary compliance agreement with Western 

Pulp and Paper Workers Local 5 in Camas, Washington, concerning a challenged election held 

in December 2012. Local 5 agreed to rerun the runoff election for finance officer and install six 

candidates who won office in the original election. The investigation concluded that Local 5 

violated its constitution and bylaws by failing to set up polls at a worksite where its members 

are employed. In addition, Local 5 disqualified six winning candidates by enforcing an 

unreasonable meeting attendance requirement after completion of the election. The

investigation established that the meeting attendance requirement was unreasonable because it 

disqualified approximately 95 percent of the members from running for elected office. The 

ballots for the Western Pulp and Paper Workers Local 5 supervised mail ballot rerun election 

were tallied in May 2013. 

IAFF International Union Enters into Voluntary Compliance Agreement with OLMS 

In April 2013, the Department entered into a voluntary compliance agreement with the 

International Association of Fire Fighters (IAFF) in Washington, D.C., concerning its July 2012 

election of officers. The IAFF agreed to conduct a new election for District 5 Vice President 
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under OLMS supervision. The investigation of the challenged election disclosed that some 

locals in District 5 failed to elect delegates and proxies by secret ballot or without proper 

nomination or election notice. OLMS was able to certify some or all of the previously elected

ex-officio delegates in 44 of the local unions. There were 71 local unions required to hold new 

nominations for delegates because they had no certified delegates. OLMS staff supervised 64 

nomination meetings and two delegate elections in person. Delegates were mailed ballots of 

varying denominations equivalent to their voting strength. Ballots were in denomination of 1, 

5, 10, 20 and 50 and were necessary to protect voter secrecy. In past elections, delegates voted a 

single ballot equivalent to their local’s voting strength.

ILWU Local 142 Agrees to Hold New OLMS Supervised Election

In April 2013, the Department entered into a voluntary compliance agreement with 

International Longshore and Warehouse Union (ILWU) Local 142 in Honolulu, Hawaii, 

concerning a challenged election held in November 2012. Local 142 agreed to conduct a new 

election for the office of Kauai Division Business Agent under OLMS supervision. The 

investigation established that a candidate for business agent campaigned on company time and 

property, and inappropriately used company bulletin boards for campaign purposes. Although 

the challenged election conducted polling at 35 sites in Kauai, the supervised election was 

conducted primarily by mail ballot election in July 2013.

Department Files Suit Against NALC Branch 2730 

In May 2013, the Department filed suit against National Association of Letter Carriers (NALC) 

Branch 2730 in Gretna, Louisiana. The lawsuit filed in the United States District Court for the 

Eastern District of Louisiana sought to void the branch’s November 2012 election for president, 

vice president, treasurer, secretary, and state and national convention delegates and to obtain a 

new election for these positions under the Secretary of Labor’s supervision. The investigation

determined that the branch failed to timely mail ballots and election notices, failed to mail 

ballots and election notices to all members, and failed to have voted ballots returned to a secure 

location. 

Machinists Local Lodge 1976 Enters Voluntary Agreement with OLMS 

In May 2013, OLMS entered into a voluntary compliance agreement with Machinists Local 

Lodge 1976, a 1,400-member union in Moon Township, Pennsylvania, concerning its December 

2012 election of officers. Local Lodge 1976 agreed to conduct a new election for president, vice 

president, recording secretary, grievance committee chair, two grievance committee positions 

and two trustees under OLMS supervision. The investigation of the challenged election 

established that employer equipment and supplies were used to produce campaign literature 

that promoted the incumbent slate of officers. The supervised poll ballot election was 

conducted in December 2013.

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 
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sessions for union members and officials on the financial reporting obligations under the 

LMRDA. 

Unions must file annual financial 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 supervision or 

control is established over a subordinate body. Other entities – 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. CBAs covering 1,000 or more workers are 

maintained by OLMS and are located at www.dol.gov/olms/regs/compliance/cba/index.htm. 

OLMS received and processed the following public disclosure reports in FY 2013.

OLMS LMRDA Reports Administration FY 2013

Form LM-1 Labor Organization Information Reports 191

Form LM-2 Labor Organization Annual Reports 4,836

Form LM-3 Labor Organization Annual Reports 11,287

Form LM-4 Labor Organization Annual Reports 7,724

Simplified Labor Organization Annual Reports 1,331

Form LM-10 Employer Reports 934

Form LM-15 Trusteeship Reports (initial, semiannual, and 15A) 226

Form LM-16 Terminal Trusteeship Reports 58

Form LM-20 Labor Relations Consultant Agreement and Activities Reports 571

Form LM-21 Labor Relations Consultant Receipts and Disbursements Reports 117

Form LM-30 Labor Organization Officer and Employee Reports 797

Form S-1 Surety Company Annual Reports 80

Total Reports 28,152

In FY 2011, OLMS introduced its new Electronic Forms System (EFS). EFS is a web-based

system for completing and submitting Labor-Management (LM) reports. Implementation of 

EFS is being conducted in phases. Currently, Form LM-2, LM-3, and LM-4 Labor Organization 

reports and Form LM-30 Labor Organization Officer and Employee reports can be filed via EFS. 

EFS allows any filer 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 not acceptable, 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, as “Special Reports” cases. 

In FY 2013, 100 percent of LM-2 filers, over 38 percent of LM-3 filers, over 32 percent of LM-4 

filers, and over 16 percent of LM-30 filers submitted their annual reports via EFS, which has 

increased timely and accurate filing. In FY 2013, OLMS exceeded its performance goal by 
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increasing the percent of all LM reports filed electronically to 42.4 percent. OLMS also tracks 

the numbers of delinquent and deficient reports and special reports cases completed. The FY 

2013 planning projections in those categories are largely based on historical averages. Enhanced 

OLMS outreach efforts have improved timely reporting compliance resulting in fewer than 

projected delinquent reports cases and special reports cases, as noted in the chart below.

OLMS Performance Goal – Reporting and Disclosure FY 2013 Target FY 2013 Results

Percent of Reports Filed Electronically 34.5% 42.4%

OLMS Enforcement Statistics – Reporting and Disclosure FY 2013 Plan FY 2013 Results

LM-2/3/4 Delinquent Reports Cases Completed 2,181 2,063

LM-2/3/4 Deficient Reports Cases Completed 214 311

Special Reports Cases Completed 79 75

4. Employee Protections

OLMS’ Division of Statutory Programs (DSP) 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 2013, DSP certified 1,902 federal transit grants, with 99.3% percent of grants (1,889 of 

1,902) certified within a 45-day timeframe, well under the 60 days permitted by 

guidelines. More information about employee protections under federal transit law can be 

found at www.dol.gov/olms/regs/compliance/compltransit.htm.

5. Compliance Assistance 

In FY 2013, 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 FY 2013, OLMS 

conducted compliance assistance seminars for 2,125 attendees. In total, OLMS recorded 

9,795 contact hours of compliance assistance (i.e., the number of participants multiplied 

by the number of hours of instruction).
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• OLMS continued to be responsive to all specific requests for compliance assistance 

seminars. OLMS received and responded to hundreds of requests for information and 

interpretations.

• OLMS maintained voluntary compliance partnerships with 40 international and national 

unions resulting in significant improvements in the reporting and bonding compliance 

of their affiliates, as well as promoting training initiatives and development of best 

practices.

• OLMS conducted a live Webinar for filers of the Form LM-30 Labor Organization Officer 

and Employee Report on how to file electronically.

• OLMS continued to promote and use an electronic mailing list system to send e-mail 

messages to unions, accountants, union members, and other interested parties. More 

than 33,000 subscribers to the Department of Labor’s electronic messaging system 

receive OLMS messages.

• OLMS managed a public email address, enabling it to respond to thousands of inquiries 

and requests in the year.

• OLMS continued its Persuader Reporting Orientation Program (PROP) for employers 

hiring consultants in National Labor Relations Board (NLRB) certification elections. 

OLMS sent a letter to all employers and representatives listed in certification petitions 

advising them of their potential reporting responsibilities under Section 203 of the 

LMRDA.